Corrective Action Plans

Finding 499583 (2023-002)

Material Weakness 2023

Manitowoc County

WI

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

Suspension and Debarment Recommendation: We recommend the County follow their suspension and debarment policy which includes maintaining documentation related to suspension and debarment for covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the findi...

Suspension and Debarment Recommendation: We recommend the County follow their suspension and debarment policy which includes maintaining documentation related to suspension and debarment for covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The County immediately began reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: JJ Gutman, Finance Director Planned completion date for corrective action plan: The County immediately began evaluating procedures and will implement as soon as possible

View Audit 322444

Finding 499582 (2023-002)

Significant Deficiency 2023

Housing Authority of the Town of Vernon

CT

HUD Housing Programs Eligibility Significant Deficiency

Response: Ensure that existing filing errors are corrected and to ensure that future filing accuracy is demonstrated. Vernon Housing is implementing the following: Vernon Housing has an existing quality control program to ensure that all HCV files are complete and up to date. In addition, Vernon Hou...

Response: Ensure that existing filing errors are corrected and to ensure that future filing accuracy is demonstrated. Vernon Housing is implementing the following: Vernon Housing has an existing quality control program to ensure that all HCV files are complete and up to date. In addition, Vernon Housing has reorganized itself with new staff being placed during the mid-year of FY23 and current. This Housing Program Manager position centralizes Housing program oversight with expertise necessary for a successful quality control system. The Agency fiscal year 2023 audit first noted the need for improved quality control Housing Choice voucher program and filing. The sample errors pointed out during the audit have been corrected and reviewed with associated personnel. Going forward since the beginning of CY 2024 the Housing program manager has reviewed all interims along with annual certifications completed by the direct reports for compliance and filing accuracy. A structured filing system has been identified for all staff personnel to follow and be assessed during the quality control review process. A monthly quality control schedule has been implemented to report to upper management during the department closing process. Management will continue to require staff to attend training and obtain the PH/HCV Specialist Certification as a mandatory job requirement. Management will continue efforts to standardize tenant files, perform supervisory and compliance file reviews and hold staff accountable for failure to adhere to the governing rules and regulations for file compliance. HCV Program staff will continue to use file review checklists when performing Recertification procedures, which require the review of Lease Addendums to ensure that the proper documentation is in the file. These are ongoing tasks. The Housing Program Manager will be responsible for these tasks. Planned Implementation Date of Corrective Action: October 2024 Person Responsible for Corrective Action: Shenoa Steves-Housing Program Manager

View Audit 322442

Finding 499581 (2023-001)

Material Weakness 2023

Whatcom County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Corrective action the auditee plans to take in response to the finding: Whatcom County’s primary internal control over federal grant compliance is the requirement that grant administrators to attend federal grant training. Whatcom County will evaluate the feasibility of adding an additional interna...

Corrective action the auditee plans to take in response to the finding: Whatcom County’s primary internal control over federal grant compliance is the requirement that grant administrators to attend federal grant training. Whatcom County will evaluate the feasibility of adding an additional internal control of checking for debarment when a vendor is set in our accounting system and there after checking for debarment every calendar year before purchase orders are issued.

View Audit 322440

Finding 499571 (2023-004)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

Questioned Costs Special Tests & Provisions Significant Deficiency

Response to Finding 2023-004 The Authority generally concurs with the auditor’s findings and recommendations regarding the handling of HQS deficiencies. To address this, the Authority will implement a more rigorous process to ensure timely correction of deficiencies and adherence to abatement proced...

Response to Finding 2023-004 The Authority generally concurs with the auditor’s findings and recommendations regarding the handling of HQS deficiencies. To address this, the Authority will implement a more rigorous process to ensure timely correction of deficiencies and adherence to abatement procedures. 1. Enhanced Correction Process: • Effective October 2024, the Authority will introduce stricter timelines and automated reminders for staff to manage I IQS deficiencies. • Tf a deficiency is not corrected within the timeframe specified in the HAKC HCV Admin Plan, it will automatically escalate to the HCV Inspection Manager and Supervisor for immediate action. • Immediate actions include placing the unit on hold in the Elite system, issuing a notice to the landlord and participant, and sending an email to the Specialist to issue a voucher for the participant to move, if necessary. • A formal letter will be sent to both the landlord and tenant notifying them of the identified deficiencies, along with a set timeframe of 30 days for the repairs to be completed. A re-inspection date will be scheduled to verify that repairs have been made. 2. Abatement Process: • If repairs are not made by the set re-inspection date, an abatement letter will be sent to both the landlord and tenant, notifying them that HAP payments will cease on the first day of the following month, providing a minimum of 30 days' notice. • At this time, a letter will also be sent to the tenant notifying them that a voucher will be issued to allow them to move to a more suitable unit. 3. Termination of HAP Contract: • If repairs are still not completed by the end of the 30-day abatement period, the HAP contract will be terminated along with the HAP payment. A termination of HAP letter will be sent to the landlord and tenant for the current unit. 4. Documentation and Review Process: • The Inspection Department will maintain a weekly abatement spreadsheet documenting the reason for abatement, the start and end dates of the abatement, and any associated inspection reports. • This spreadsheet, along with the abated inspection documentation, will be reviewed at the beginning and end of each month before closeout to ensure that the abatement process is properly initiated and managed. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024 If the Department of Housing and Urban Development has questions regarding this plan, please call LaMonyka French, Deputy, Executive Director at (816) 968-4100.

View Audit 322424 Questioned Costs: $1

Finding 499570 (2023-003)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Response to Finding 2023-003 The Authority generally concurs with the auditor’s findings and recommendations. To address the finding related to inadequate documentation for rent reasonableness determinations, the Authority will implement the following corrective actions: 1. Immediate and Ongoing Tra...

Response to Finding 2023-003 The Authority generally concurs with the auditor’s findings and recommendations. To address the finding related to inadequate documentation for rent reasonableness determinations, the Authority will implement the following corrective actions: 1. Immediate and Ongoing Training: • To ensure consistency, increase staff knowledge, and reduce errors, the Authority will conduct immediate training sessions for all relevant staff, followed by annual refresher training. These sessions will focus on the correct procedures for documenting rent reasonableness and the importance of maintaining accurate and complete records. 2. Enhanced Quality Control and Error Monitoring: • The Authority will increase the frequency of quality control file reviews to identify errors promptly and address their root causes to prevent systemic issues. • Errors will be tracked by type and by the staff member responsible, allowing for the identification of patterns. Additional training will be provided for common error types and to individuals who are frequently responsible for errors. 3. Comprehensive File Reviews: • Quality reviews will be conducted on all files to ensure the presence of all required documents. It is anticipated that the initial comprehensive file review will take approximately one year to complete. • After the initial review, files will be selected randomly for review according to an established quality control schedule. This ongoing review process will ensure continuous compliance and address any issues as they arise. 4. Responsibility for Document Collection: • Each team member will be responsible for collecting any missing documents identified during the annual recertification, interim recertification, or change of unit processes. This accountability measure ensures that all necessary documentation is gathered and maintained consistently. 5. Adoption of a Digital Platform: • As part of the corrective action, the Authority has adopted a digital platform that requires the completion of all necessary fields before a rent determination can be finalized. This platform will also retain all documentation used to determine rent reasonableness for at least two years, ensuring thorough and accessible records. 6. Increased Random Audits: • Effective October 2024, random audits will be increased to monthly reviews to identify any discrepancies early and to ensure ongoing compliance with documentation requirements. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024

View Audit 322424

Finding 499569 (2023-002)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Reporting Significant Deficiency

Response to Finding 2023-002 The Authority generally concurs with the auditor’s findings and recommendations. The Authority has implemented procedures to ensure recertifications are promptly uploaded to the PIC system. Effective August 2024, we have adopted a system that flags any recertification no...

Response to Finding 2023-002 The Authority generally concurs with the auditor’s findings and recommendations. The Authority has implemented procedures to ensure recertifications are promptly uploaded to the PIC system. Effective August 2024, we have adopted a system that flags any recertification not uploaded to PIC. A HAKC Quality Control employee is responsible for daily uploads from Monday through Friday. With each upload, any fatal errors encountered are documented in an Excel spreadsheet. Once the error has been corrected in the PIC system, the correction is recorded on the spreadsheet, and the corresponding green status from PIC is printed for documentation, confirming that the issue has been resolved. To maintain ongoing compliance, bi-weekly audits will be conducted to verify that no files are missing from the PIC system. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024

View Audit 322424

Finding 499568 (2023-001)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Response to Finding 2023-001 The Authority generally concurs with the auditor’s findings and recommendations. To address these issues, the Authority has implemented the following corrective actions: 1. Mandatory Refresher Training: • Effective May 2024, the Authority has rolled out mandatory refresh...

Response to Finding 2023-001 The Authority generally concurs with the auditor’s findings and recommendations. To address these issues, the Authority has implemented the following corrective actions: 1. Mandatory Refresher Training: • Effective May 2024, the Authority has rolled out mandatory refresher training for all relevant staff on eligibility documentation and recertification processes. This training ensures that all staff are fully aware of the correct procedures and policies, and that they understand the importance of maintaining complete and accurate tenant files and performing recertifications in a timely manner. 2. Implementation of a New Tracking System: • A new tracking system has been implemented to ensure that all documentation is completed timely and verified by a supervisor. This system allows for real-time monitoring of the documentation process, ensuring that all required documents are included in the tenant files. 3. Utilization of Checklists: • The Authority has introduced a mandatory checklist that staff are required to use every time a file is accessed or updated. This checklist serves as a tool to ensure that all necessary steps are taken, and all required documentation is included in the tenant file. 4. Enhanced Monitoring by HCV Director and Supervisors: • The HCV Director and Supervisors will closely monitor the recertification process to ensure that all recertifications are completed in a timely manner and in accordance with policy. This includes ensuring that all participants receive and return their recertification paperwork as required. 5. Increased Frequency of Quality Control Reviews: • The Authority will continue to conduct quality control file reviews and will increase the frequency of these reviews to identify errors sooner. This proactive approach will help address the root causes of errors quickly and prevent systemic issues from developing. 6. Ongoing Quality Reviews: • Continuous quality reviews will be conducted for all files to ensure that all required documents are present and that all recertifications are performed on time. This ongoing process is designed to maintain high standards of accuracy and compliance in tenant file management. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024

View Audit 322424

Finding 499561 (2023-001)

Significant Deficiency 2023

Early Childhood Connections

SD

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No. 2023-001: Written Uniform Guidance Policies Responsible Individuals: Autumn Gregory, Executive Director Corrective Action Plan: The Organization will develop written Uniform Guidance policies. Anticipated Completion Date: December 31, 2024

View Audit 322422

Finding 499559 (2023-001)

Significant Deficiency 2023

Nonprofit Finance Fund and Affiliate

NY

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.430

Planned Corrective Action: NFF revised current year SEFA for expenses which did not meet the compliance requirement. In addition, management implemented review control whereby the expenditures will be reviewed to ensure compliance with federal agency requirements. Beginning in August 2024, NFF wil...

Planned Corrective Action: NFF revised current year SEFA for expenses which did not meet the compliance requirement. In addition, management implemented review control whereby the expenditures will be reviewed to ensure compliance with federal agency requirements. Beginning in August 2024, NFF will update its time and effort management and review of employees who perform work related to federal grants. This includes circulating a tracking spreadsheet monthly to relevant staff to certify their time and effort spent on eligible activities allowable for grant expenditure relative to their overall work performed, which will be used for salary and benefit allocations. The Finance team will circulate the spreadsheet first to relevant staff members for certification, and then department heads for management review and approval. For department head time and effort review and approval, the executive suite will review and approve. The spreadsheet and approvals will be saved as back up for the allocations each month.

View Audit 322416 Questioned Costs: $1

Finding 499558 (2023-002)

Material Weakness 2023

Dairy Grazing Apprenticeship, Inc.

WI

Allowable Costs / Cost Principles

The Organization will conduct quarterly time studies by position and make adjustments to allocations as time spent deviates from the most recent time study or original budget. We will utilize our outsourced accounting firm to assist in preparing a time study template and will utilize our audit firm ...

The Organization will conduct quarterly time studies by position and make adjustments to allocations as time spent deviates from the most recent time study or original budget. We will utilize our outsourced accounting firm to assist in preparing a time study template and will utilize our audit firm to confirm these time studies meet Uniform Guidance Requirements.

View Audit 322414

Finding 499557 (2023-001)

Significant Deficiency 2023

America's Poison Centers

VA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Views of Responsible Officials: In 2024, the recommendation was implemented. Allocations will be reviewed by the outsourced accounting team to ensure that this has been executed upon. The CEO is responsible for overseeing both the new HR service provider and the outsourced accounting team and will e...

Views of Responsible Officials: In 2024, the recommendation was implemented. Allocations will be reviewed by the outsourced accounting team to ensure that this has been executed upon. The CEO is responsible for overseeing both the new HR service provider and the outsourced accounting team and will ensure that this does not recur.

View Audit 322412

Finding 499556 (2023-005)

Material Weakness 2023

Fulton County

IN

Procurement, Suspension & Debarment § 200.1 § 200.214 § 200.303 § 200.317 § 200.318

FINDING 2023-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Procurement - Policy The County had not established a purchasing policy that would reflect applicable state laws and regulations including pro...

FINDING 2023-005 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment Summary of Finding: Procurement - Policy The County had not established a purchasing policy that would reflect applicable state laws and regulations including procedures to avoid acquisition of unnecessary or duplicative items, procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured and did not maintain written standards of conduct covering conflicts of interest and governing actions of its employees engaged in the selection, award, and administration of contracts. Procurement – Small Purchases The County had one vendor that was identified as being less than the simplified acquisition threshold of $150,000 but exceeding the $50,000 micro-purchase threshold. The one vendor was selected for testing. For the one vendor, the County did not obtain price or rate quotes nor was there documentation detailing the history of procurement, which must include the reason for the procurement method used. Suspension and Debarment One covered transaction paid with SLFRF grant funds was identified during the audit period. The covered transaction totaled $66,000 with $46,752 paid in the audit period. Upon review, the County had not performed procedures to ensure the vendor was not suspended or debarred, or otherwise excluded or disqualified, from participation in federal assistance programs or activities at any time during the audit period Contact Person Responsible for Corrective Action: Bryan Lewis Contact Phone Number and Email Address: 574-223-4764 and blewis@co.fulton.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County will work on establishing a purchasing policy which will address federal procurement requirements. Before entering into contracts we will ensure the procurement procedures in the policy are followed and obtain quotes for vendors that meet the small purchase threshold as well as verify the suspension and debarment status. The Commissioners and Auditor’s office will work together to ensure requirements are met before payment is processed. Anticipated Completion Date: No later than December 31, 2024

View Audit 322411

Finding 499555 (2023-004)

Material Weakness 2023

Fulton County

IN

Reporting § 200.1 § 200.303

FINDING 2023-004 Finding Subject : COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the P&E report on June 16, 2023, which was 47 days after the due date. Additionally, the report was not mathematically accurate and complete. The key l...

FINDING 2023-004 Finding Subject : COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the P&E report on June 16, 2023, which was 47 days after the due date. Additionally, the report was not mathematically accurate and complete. The key line items of "Total Cumulative Expenditures" and "Current Period Expenditures" as reported on the P&E report did not agree to the County's ledger. Contact Person Responsible for Corrective Action: Christina Sriver Contact Phone Number and Email Address: 574-223-2912 and auditor@co.fulton.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Upon initial discussion of the Coronavirus State and Local Fiscal Recovery Funds report with State Board of Accounts a deputy auditor began to review the files and financial tracking. This employee will work to update all expenditures of the CSLFR funds to ensure accuracy on the upcoming report and submit timely. Anticipated Completion Date: No later than December 31, 2024

View Audit 322411

Finding 499554 (2023-001)

Material Weakness 2023

Des Moines Valley Health and Human Services

MN

Internal Control / Segregation of Duties

Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will continue to review and gain an understanding of the audit adjustments in order to reduce the number of entries necessary for future audits. Offici...

Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will continue to review and gain an understanding of the audit adjustments in order to reduce the number of entries necessary for future audits. Official Responsible for Ensuring CAP: Natane Sadusky, Director of Business Management, is the official responsible for ensuring corrective action of the significant deficiency. Planned Completion Date for CAP: December 31, 2024 Plan to Monitor Completion of CAP: The Agency Board will be monitoring this corrective action plan.

View Audit 322409

Finding 499553 (2023-002)

Material Weakness 2023

Putnam County

IN

Internal Control / Segregation of Duties Reporting Allowable Costs / Cost Principles § 200.1 § 200.303

FINDING 2023-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The SLRF report did not include project information or amounts. Contact Person Responsible for Corrective Action: Auditor Contact Phone Number and Email Address: 765-653-551...

FINDING 2023-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The SLRF report did not include project information or amounts. Contact Person Responsible for Corrective Action: Auditor Contact Phone Number and Email Address: 765-653-5513, auditor@putnam.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: We have reached out to Baker Tilly, who does the reports for the County, regarding our audit finding so they know the reporting requirements that will need to be done for the next project and expenditure report which is due to be filed by April 30, 2025. Once we receive the report from Baker Tilly we will have a county employee review for accuracy of the report. Anticipated Completion Date: April 30, 2025

View Audit 322406

Finding 499549 (2023-002)

Significant Deficiency 2023

Lakewood Resource & Referral Center-D/b/a/ Center for Health Education

NJ

Special Tests & Provisions Eligibility Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN September 27, 2024 Health Resources and Services Administration Lakewood Resource and Referral Center, Inc. D/B/A Center for Health Education, Medicine and Dentistry respectfully submits the following corrective action plan for the year ended December 31, 2023. _____________...

CORRECTIVE ACTION PLAN September 27, 2024 Health Resources and Services Administration Lakewood Resource and Referral Center, Inc. D/B/A Center for Health Education, Medicine and Dentistry respectfully submits the following corrective action plan for the year ended December 31, 2023. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2023 The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT FINDINGS Finding 2023-001 – Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Center ensure that all accounting records are analyzed and reconciled on a monthly basis. We also recommend that necessary procedures be enhanced whereby an employee of the Center consistently reviews and follows up on receivables and adjusts the reserves for those receivables appropriately. This will help accurately reflect the cash realizable value of receivables. This will provide the Center with a stronger accounting of patient services receivable with which to better manage cash collections. We also recommend that the Center perform the patient services revenue reconciliation by payor source on a monthly basis. This would help the Center determine whether patient services revenue is being properly recorded by payor source. Action Taken Management of the Center agrees with the finding and has started to work with a new general ledger software package at the start of 2024, to better accommodate monthly reconciliations. We will also ensure that these analyses and reconciliations will be reviewed on a consistent and timely basis. There has been steady improvement throughout 2024, and it is expected to be complete by the end of 2024. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, COVID-19 Health Centers Program Cluster (Assistance Listing Number 93.224/93.527) Finding 2023-002 – Special Tests and Provisions SIGNIFICANT DEFICIENCY Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are being properly calculated. Supervisors should monitor and review the sliding fee calculations on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Action Taken Management of the Center is providing additional training to the relevant staff that deal with the Sliding Fee Discount (SFD). These staff members include front desk staff, financial counselors, and the general finance and billing departments, as applicable. The SFD Policy and SFD Scale are being reviewed by management to ensure that the guidelines and procedures are clear. Revisions to the SFD Policy and SFD Scale will be made, and Board approved, if necessary to improve clarity. To ensure that the SFD is being properly calculated in accordance with the SFD Scale, a monitoring process will be included, which may include internal periodic audits by supervisors. All changes will be finalized and implemented by the end of 2024. If the Health Resources and Services Administration has questions regarding this plan, please call Scott Jackson, Chief Financial Officer at (732) 364-2144 x6138. Sincerely yours, Scott Jackson, CFO

View Audit 322404

Finding 499548 (2023-001)

None 2023

Altamed Health Services Corporation

CA

Reporting

Views of Responsible Officials and Planned Corrective Actions: AltaMed implemented a monthly review of the Payment Management System to be performed the first week of each month to ensure FFR report due dates are identified, documented and submitted 10 days prior to the deadline. If required informa...

Views of Responsible Officials and Planned Corrective Actions: AltaMed implemented a monthly review of the Payment Management System to be performed the first week of each month to ensure FFR report due dates are identified, documented and submitted 10 days prior to the deadline. If required information is not available, AltaMed will contact the HRSA Program Officer to request a documented extension.

View Audit 322403

Finding 499547 (2023-001)

Significant Deficiency 2023

The Spero Project, Inc.

OK

Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.302 § 200.303 § 200.305

CORRECTIVE ACTION PLAN The Spero Project, Inc. ( “Organization”), respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: HSPG & Associates, 5400 N. Grand Blvd., Suite 330, Oklahoma City, OK 73112. ...

CORRECTIVE ACTION PLAN The Spero Project, Inc. ( “Organization”), respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: HSPG & Associates, 5400 N. Grand Blvd., Suite 330, Oklahoma City, OK 73112. Audit period: As of and for the year ended December 31, 2023. The findings from the December 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS – COMPLIANCE AND INTERNAL CONTROL Identifying Number: 2023-001; Lack of Written Policies and Procedures Recommendation: The Organization should develop and implement comprehensive written policies and procedures in accordance with the requirements of the Uniform Guidance. These should include, but not be limited to, the following areas: 1. Financial management, including procedures for payments and cash management. 2. Internal controls to ensure compliance with federal requirements. 3. Determination of allowable costs in accordance with federal regulations and the terms and conditions of the award. 4. Procurement standards and conflict of interest policies. 5. Time and effort reporting and compensation. The Organization should also ensure that staff are adequately trained in these policies and procedures to enhance compliance and operational efficiency. Action Taken: In response to the finding, management and will take action to develop and implement the necessary written policies and procedures by December 31, 2024. Comprehensive training will be provided to all relevant staff to ensure compliance with federal requirements. Anticipated completion date: December 31, 2024 Name of contact person and title: Ms. Kim Bandy, Executive Director

View Audit 322401

Finding 499546 (2023-006)

Significant Deficiency 2023

Town of Fountain City

IN

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.328

Finding 2023-006 – Coronavirus State and Local Fiscal Recovery Funds - Reporting (Significant Deficiency) Criteria: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal aw...

Finding 2023-006 – Coronavirus State and Local Fiscal Recovery Funds - Reporting (Significant Deficiency) Criteria: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Context: There was no documented review by someone other than the preparer of the annual report to ensure the information submitted was complete and accurate. Per discussion with management, verbal review occurred but there is no documentation to support that review occurred. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that review of the annual report is documented. Responsible Party and Timeline for Completion: The Clerk-Treasurer is the responsible party. The completion will go into effect in 2024.

View Audit 322400

Finding 499544 (2023-005)

Material Weakness 2023

Town of Fountain City

IN

Procurement, Suspension & Debarment § 200.303

Finding 2023-005 – Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment (Material Weakness) Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides r...

Finding 2023-005 – Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment (Material Weakness) Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR section 200.303 states in part: "The non-Federal entity must use one of the following methods of procurement… (b) Simplified acquisition thresholds. The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations. Context: For one procurement, it was noted that the Town did not have documented support of all quotes obtained. Management had support for one quote and noted that a second quote was obtained verbally. Management’s procurement policy states that three quotes must be obtained and the contract must be awarded to the lowest bid. Management did not document the basis for purchasing from the vendor that was utilized. Additionally, for one of the two procurements tested, management did not provide support indicating that the Town verified the vendor was not debarred or suspended. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that the adopted procurement policy is followed and documents to support the process are maintained. Responsible Party and Timeline for Completion: The Clerk-Treasurer is the responsible party. The completion will go into effect in 2024.

View Audit 322400

Finding 499543 (2023-004)

Material Weakness 2023

Perry County

IN

Allowable Costs / Cost Principles Material Weakness Reporting § 200.1 § 200.303

FINDING 2023-004 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Summary of Finding: Perry County did not properly report period expenditures. The County submitted one P&E report during the audit period. Although the Deputy Auditor compiled the information fo...

FINDING 2023-004 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Summary of Finding: Perry County did not properly report period expenditures. The County submitted one P&E report during the audit period. Although the Deputy Auditor compiled the information for the report and the County Auditor reviewed and submitted the report, the internal controls were not effective in preventing, or detecting and correcting, errors. As a result, the P&E report contained errors. Contact Person Responsible for Corrective Action: Kristinia L. Hammack, Perry County Auditor Contact Phone Number: (812) 547-6427 Views of Responsible Officials: We concur with the audit finding. Description of Corrective Action Plan: The Auditor is now aware that the P&E Reporting Period is not calendar. All internal control will stay in place and this information will be noted for further SLFRF Reporting. The Auditor will review the reports prior to submission to ensure that the reporting period is not on a calendar year when reporting. Completion Date: March 1, 2025 INDIANA STATE

View Audit 322397

Finding 499542 (2023-003)

Material Weakness 2023

Perry County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.214 § 200.303

FINDING 2023-003 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: The ineffective internal controls resulting in a failure of having processes and procedures in place to prohibit from contracting with or making subawards under cover...

FINDING 2023-003 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: The ineffective internal controls resulting in a failure of having processes and procedures in place to prohibit from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. Contact Person Responsible for Corrective Action: Kristinia L. Hammack, Perry County Auditor Contact Phone Number: (812) 547-6427 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Currently, the County requires all new vendors to complete a “Vendor Registration Form”. A new step that Procurement implemented as of September 30, 2024 will be verification of vendor’s status on sam.gov and attaching the screenshot to the LOW system. Procurement will update their vendor policy to specifically include this step. The Auditor’s Office will check incoming contracts from departments to ensure proper documentation is attached that verifies the vendor has been checked through sam.gov and in.gov. Once the contract has been approved by the Commissioners, the Auditor’s office will then upload the contract and supporting documents into Gateway. Anticipated Completion Date: September 30, 2024

View Audit 322397

Finding 499541 (2023-004)

Material Weakness 2023

Tongue River Valley Joint Powers Board

WY

Material Weakness Internal Control / Segregation of Duties § 200.512

2023-004 Audit Report Submission to Federal Government Material Weakness in Internal Control over Compliance The Chairman of the Tongue River Valley Joint Powers Board will diligently comply with the Federal Reporting deadlines now that a consistent relationship has been established with an auditing...

2023-004 Audit Report Submission to Federal Government Material Weakness in Internal Control over Compliance The Chairman of the Tongue River Valley Joint Powers Board will diligently comply with the Federal Reporting deadlines now that a consistent relationship has been established with an auditing firm. Ongoing process.

View Audit 322395

Finding 499540 (2023-003)

Significant Deficiency 2023

Tongue River Valley Joint Powers Board

WY

Questioned Costs Procurement, Suspension & Debarment Significant Deficiency § 200.326

2023-003 Uniform Guidance Written Policies and Procedures Significant Deficiency in Internal Control and Compliance According to the USDA-RD, the Tongue River Valley Joint Powers Board/The Tongue River Gas distribution project is exempt from being compliant with the Davis Bacon Labor Laws. Therefore...

2023-003 Uniform Guidance Written Policies and Procedures Significant Deficiency in Internal Control and Compliance According to the USDA-RD, the Tongue River Valley Joint Powers Board/The Tongue River Gas distribution project is exempt from being compliant with the Davis Bacon Labor Laws. Therefore, the Board believes this finding is not applicable. The bidding and bonding process for the construction of the Natural Gas Distribution system complied with all Federal Regulations. The current activities are funded by user fee which are in part used to make loan payments.

View Audit 322395 Questioned Costs: $1

Finding 499539 (2023-002)

None 2023

Tongue River Valley Joint Powers Board

WY

Matching / Level of Effort / Earmarking

2023-002 Loan Reserve Requirement Non-Compliance The Chairman of the Tongue River Valley Joint Powers Board will continue to work with USDA-RD to find ways to address this issue. The Board and the USDA are looking to sell Tongue River Gas to a third party or put it up for auction in the near future.

View Audit 322395

Corrective Action Plans

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