Findings Citing § 200.400

2022-002 - Deficient Federal Cost Principles Policies and Procedures Finding Type: Material Weakness and Noncompliance over Federal Awards Programs: Capitalization Grants for Clean Water Revolving Funds (Assistance Listing Number 66.458) Criteria: Per 2 CFR Subpart E - Cost Principles, ? 200.400 Policy guide: The application of these cost principles is based on the fundamental premises that: (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. (c) The non-Federal entity, in recognition of its own unique combination of staff, facilities, and experience, has the primary responsibility for employing whatever form of sound organization and management techniques may be necessary in order to assure proper and efficient administration of the Federal award. Condition/Finding: We examined $1,746,599 of federal funds reimbursed to the City from the State Revolving Fund award during the year. Management informed us and we verified that $134,102 of reimbursements were for ineligible construction costs as these amounts were bid alternates that were not allowed uses of the federal award. Further, management informed us and we verified that $17,253 of federal reimbursements were received for a duplicate construction invoice. Further, as a result of reviewing the ineligible costs, management found that in fiscal year 2021, ALN 66.458 included $5,768 in ineligible expenditures, and the overall total expenditures was understated by $184,073. In addition, ALN 14.228 had expenditures of $229,554 that were understated in fiscal year 2021, and ALN 10.760 had expenditures totaling $81,228 that were understated in fiscal year 2021. Cause: The City did not have written policies and procedures over cost principles as required by the Uniform Guidance. Further, the informal policies and procedures that were followed by the City were not effectively designed. The ineffective design allowed an individual to prepare and submit reimbursement requests for federal funds without appropriate review in place to prevent and detect reimbursement reporting and submission errors. Effect: The City?s controls over cost principles were found to be ineffective. Additionally, the City was noncompliant with cost principal requirements and received reimbursements of $151,355 that were subsequently found (by new management) to be ineligible. Questioned Costs: $151,355 costs have been questioned as a result of this finding. Repeat Finding: No Recommendation: We recommend that the City Commission and management adopt, and follow, written policies and procedures (that conform with requirements of the Uniform Guidance) to ensure that future grant and/or loan reimbursements are properly reported, documented, and reviewed by individuals with appropriate knowledge of the award to prevent ineligible costs from being received by the City. View of Responsible Officials (Corrective Action): See corrective action plan.

FINDING 2022-011 Subject: Title I Grants to Local Educational Agencies - Level of Effort-Maintenance of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A190014SIG Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective system of internal controls was not in place at the School Corporation in order to ensure compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Level of Effort-Maintenance of Effort Maintenance of Effort is a district-level test that determines whether the School Corporation is providing a consistent level of financial support to public schools from year-to-year. This rule ensures that the School does not use Title I funds to shore up reductions in state and local support for public education. The Indiana Department of Education (IDOE) performs the Maintenance of Effort calculation utilizing Form 9 information provided by the School. As such, the amounts submitted to the IDOE to be used in the computation are tested to ensure they were recorded properly in the School's records as to the account and object code. In the fiscal years 2020-2021 and 2021-2022, 60 transactions were sampled each year to ensure the disbursements were posted to the proper account and object code. For 16 of the 60 transactions selected in 2020-2021, as well as 21 of the 60 transactions selected in 2021- 2022, appropriate supporting documentation was not provided for audit. As a result, the 37 disbursements could not be verified as to whether they were posted to the proper accounts and object codes. Earmarking The School Corporation did not expend the required minimum amount from grant S010A190014 for parent involvement activities. The School also did not have policies or procedures in place to properly monitor the expenses for the Parent Involvement set-aside to ensure the mandatory amounts were spent for both the S010A190014 and the S010A200014 grants. In addition, the Homeless set-asides for grants S010A190014 and S010A200014 were not monitored to ensure expenditures were tracked for those students designated as homeless. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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 200.400 states in part: "(a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-011 Subject: Title I Grants to Local Educational Agencies - Level of Effort-Maintenance of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A190014SIG Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective system of internal controls was not in place at the School Corporation in order to ensure compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Level of Effort-Maintenance of Effort Maintenance of Effort is a district-level test that determines whether the School Corporation is providing a consistent level of financial support to public schools from year-to-year. This rule ensures that the School does not use Title I funds to shore up reductions in state and local support for public education. The Indiana Department of Education (IDOE) performs the Maintenance of Effort calculation utilizing Form 9 information provided by the School. As such, the amounts submitted to the IDOE to be used in the computation are tested to ensure they were recorded properly in the School's records as to the account and object code. In the fiscal years 2020-2021 and 2021-2022, 60 transactions were sampled each year to ensure the disbursements were posted to the proper account and object code. For 16 of the 60 transactions selected in 2020-2021, as well as 21 of the 60 transactions selected in 2021- 2022, appropriate supporting documentation was not provided for audit. As a result, the 37 disbursements could not be verified as to whether they were posted to the proper accounts and object codes. Earmarking The School Corporation did not expend the required minimum amount from grant S010A190014 for parent involvement activities. The School also did not have policies or procedures in place to properly monitor the expenses for the Parent Involvement set-aside to ensure the mandatory amounts were spent for both the S010A190014 and the S010A200014 grants. In addition, the Homeless set-asides for grants S010A190014 and S010A200014 were not monitored to ensure expenditures were tracked for those students designated as homeless. The lack of internal controls and noncompliance were systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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 200.400 states in part: "(a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective system of internal controls and retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

2022-054 Department of Human Services/Oregon Health Authority Improve controls over payments for Medicaid clients Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 2105OR5MAP, 2021; 2105OR5ADM, 2021; 2205OR5MAP, 2022; 2205OR5ADM, 2022 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.1(1); 2 CFR 200.400(a); 2 CFR 200.404; 42 CFR ? 433.32(a) Federal regulations only allow the Medicaid program to charge allowable program expenditures at the federal financial participation rate for various program costs at the time of payment for services provided. The Department of Human Services (department) and the Oregon Health Authority (authority) make payments to service providers through the Jsystems system. We randomly sampled 61 clients and one Medicaid service payment associated with each client using a statistically valid sample. We reviewed agency documentation to test compliance with the Activities Allowed or Unallowed & Allowable Cost requirements. For 1 client, we found the issues described below. ? The claim selected as our sample item did not have mileage accurately calculated, which resulted in an overpayment. Further review of payments for this client identified additional inaccurate payments during the fiscal year for mileage to this provider. Questioned costs identified for our sample item resulted in an overpayment of $6.00 and other identified questioned costs resulted in an underpayment of ($5.27). The above issues occurred due to human error when entering mileage into the state payment system from the home care worker mileage tracking software (OR-PTC), which lead to improper payments. Phase 1 of the OR-PTC system was implemented in September of 2021. During this phase of the implementation branches must run a report of mileage claims and enter these claims manually into the payment system. Due to the exceptions noted above, we reviewed all clients within our sample for the fiscal year which had mileage entered into the OR-PTC system and identified multiple additional underpayments and overpayments that resulted in an overall underpayment of ($49.07). Due to the systemic nature of this issue, we are unable to reasonably estimate or quantify remaining potential questioned costs outside of our sample population. We recommend department and authority management strengthen controls over the OR-PTC system to ensure transactions are adequately supported and reviewed.

2022-055 Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 2105OR5MAP, 2021; 2105OR5ADM, 2021; 2205OR5MAP, 2022; 2205OR5ADM, 2022 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $47,942 (known) Criteria: 2 CFR 200.1(1); 2 CFR 200.400(a); 2 CFR 200.404; 42 CFR ? 433.32(a) Federal regulations only allow the Medicaid program to charge allowable program expenditures at the federal financial participation rate for various program costs at the time of payment for services provided. The Department of Human Services (department) and the Oregon Health Authority (authority) make payments to vendors other than providers through the state?s accounting system. We judgmentally selected payments to 28 vendors for our review. We identified the following 2 errors, which were not identified during their review process, that resulted in improper payment of Medicaid expenditures: ? Payments to one vendor charged expenditures related to a specific project unrelated to the Medicaid program, resulting in known federally funded questioned costs of $1,361. ? For one payment management was unable to provide a contract or support for bids collected for the project charged to the Medicaid program, resulting in known federally funded questioned costs of $46,581. The above issues occurred due to human error and inadequate record maintenance which could lead to unallowed activities/costs being charged to the Medicaid program. We recommend department and authority management strengthen controls over review to ensure transactions are adequately supported and reviewed. Additionally, we recommend the authority reimburse the federal agency for unallowable costs.

2022-054 Department of Human Services/Oregon Health Authority Improve controls over payments for Medicaid clients Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 2105OR5MAP, 2021; 2105OR5ADM, 2021; 2205OR5MAP, 2022; 2205OR5ADM, 2022 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.1(1); 2 CFR 200.400(a); 2 CFR 200.404; 42 CFR ? 433.32(a) Federal regulations only allow the Medicaid program to charge allowable program expenditures at the federal financial participation rate for various program costs at the time of payment for services provided. The Department of Human Services (department) and the Oregon Health Authority (authority) make payments to service providers through the Jsystems system. We randomly sampled 61 clients and one Medicaid service payment associated with each client using a statistically valid sample. We reviewed agency documentation to test compliance with the Activities Allowed or Unallowed & Allowable Cost requirements. For 1 client, we found the issues described below. ? The claim selected as our sample item did not have mileage accurately calculated, which resulted in an overpayment. Further review of payments for this client identified additional inaccurate payments during the fiscal year for mileage to this provider. Questioned costs identified for our sample item resulted in an overpayment of $6.00 and other identified questioned costs resulted in an underpayment of ($5.27). The above issues occurred due to human error when entering mileage into the state payment system from the home care worker mileage tracking software (OR-PTC), which lead to improper payments. Phase 1 of the OR-PTC system was implemented in September of 2021. During this phase of the implementation branches must run a report of mileage claims and enter these claims manually into the payment system. Due to the exceptions noted above, we reviewed all clients within our sample for the fiscal year which had mileage entered into the OR-PTC system and identified multiple additional underpayments and overpayments that resulted in an overall underpayment of ($49.07). Due to the systemic nature of this issue, we are unable to reasonably estimate or quantify remaining potential questioned costs outside of our sample population. We recommend department and authority management strengthen controls over the OR-PTC system to ensure transactions are adequately supported and reviewed.

2022-055 Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 2105OR5MAP, 2021; 2105OR5ADM, 2021; 2205OR5MAP, 2022; 2205OR5ADM, 2022 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $47,942 (known) Criteria: 2 CFR 200.1(1); 2 CFR 200.400(a); 2 CFR 200.404; 42 CFR ? 433.32(a) Federal regulations only allow the Medicaid program to charge allowable program expenditures at the federal financial participation rate for various program costs at the time of payment for services provided. The Department of Human Services (department) and the Oregon Health Authority (authority) make payments to vendors other than providers through the state?s accounting system. We judgmentally selected payments to 28 vendors for our review. We identified the following 2 errors, which were not identified during their review process, that resulted in improper payment of Medicaid expenditures: ? Payments to one vendor charged expenditures related to a specific project unrelated to the Medicaid program, resulting in known federally funded questioned costs of $1,361. ? For one payment management was unable to provide a contract or support for bids collected for the project charged to the Medicaid program, resulting in known federally funded questioned costs of $46,581. The above issues occurred due to human error and inadequate record maintenance which could lead to unallowed activities/costs being charged to the Medicaid program. We recommend department and authority management strengthen controls over review to ensure transactions are adequately supported and reviewed. Additionally, we recommend the authority reimburse the federal agency for unallowable costs.

MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE AND MATERIAL NONCOMPLIANCE ? U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES ? FEDERAL ALN 84.010 2022-003 Internal Control and Noncompliance With Allowable Cost Requirements Criteria ? 2 CFR ? 200.400 (i) requires Independent School District No. 624 (the District) to maintain records that adequately and accurately identify the source and application of funds for federally-funded activities to ensure the proper determination of allowable costs in accordance with 2 CFR 200 Subpart E ? Cost Principles. Condition ? During our audit, we noted that the District did not have sufficient controls to ensure proper determination of allowable costs charged to federal programs and compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) allowable costs standards, which resulted in noncompliance. Questioned Costs ? $26,466. Context ? The District did not properly determine the allowable costs for salaries for 2 of 3 employees sampled. This was not a statistically valid sample. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel. Effect ? Noncompliance with the allowable costs requirements resulted in the District receiving reimbursements for unsupported costs. Recommendation ? We recommend that the District review its internal control procedures relating to documentation and determination of allowable costs for its Title I federal program. View of Responsible Official and Planned Corrective Actions ? The District agrees with the finding. The District will review and update its policies and procedures relating to documentation and determination of allowable costs for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.

FINDING 2022-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 20619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have effective internal controls in place to ensure that the required level of expenditures for non-public students for private school and homeschooled students were met. The School Corporation did not spend all of the required proportionate share for grant 20611-047-PN01. Additionally, the School Corporation did not spend any of the required proportionate share amount for grant 20619-047-PN01. For grant 20611-047-PN01, the amounts spent for one of the four teachers was not supported by timesheets. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 KANKAKEE VALLEY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2022-008 Lack of Internal Control over Activities Allowed or Unallowed and Material Weakness Allowable Costs/Cost Principles Material Noncompliance Federal Agency: U.S. Department of Education Federal Program: School Safety National Activities and Native Youth Community Programs ALN: 84.184 and 84.299 Award Numbers: S299A170061, S299A18022, S299A180025, and S18G190154 Award Years: 2017, 2018, and 2019 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Allowable cost principles are defined in 2 CFR 200.400. Condition and Context: We select a sample of 25 expenditures transactions for ALN 84.184. The District did not provide supporting documentation for 4 of these transactions. The District also did not provide detailed payroll distribution reports to select samples from. We selected 6 payroll transactions for ALN 84.184 and 15 payroll transactions for ALN 84.299. The District did not provide the auditors with supporting documentation for any of the payroll transactions selected. Cause: Lack of internal control over transactions charged to the major programs. Effect: The lack of supporting documentation allows for the potential for misstatement of expenditures being charged to the major program for which the cost is unallowable. Questioned Costs: Actual and likely questioned costs estimated to be below the reporting threshold of $25,000. Based on the auditor?s review of pay rates, all employees were being paid a reasonable amount based on the their position and the auditor?s experience with similar entities. Repeat Finding: No. We believe this to be an isolated issue due to employee turnover. Recommendation: We recommend the District adhere to their internal control policies to ensure that the regulations contained in 2 CFR 200 are followed. Management?s Response: Management agrees with this finding. See Corrective Action Plan.

Finding 2022-008 Lack of Internal Control over Activities Allowed or Unallowed and Material Weakness Allowable Costs/Cost Principles Material Noncompliance Federal Agency: U.S. Department of Education Federal Program: School Safety National Activities and Native Youth Community Programs ALN: 84.184 and 84.299 Award Numbers: S299A170061, S299A18022, S299A180025, and S18G190154 Award Years: 2017, 2018, and 2019 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Allowable cost principles are defined in 2 CFR 200.400. Condition and Context: We select a sample of 25 expenditures transactions for ALN 84.184. The District did not provide supporting documentation for 4 of these transactions. The District also did not provide detailed payroll distribution reports to select samples from. We selected 6 payroll transactions for ALN 84.184 and 15 payroll transactions for ALN 84.299. The District did not provide the auditors with supporting documentation for any of the payroll transactions selected. Cause: Lack of internal control over transactions charged to the major programs. Effect: The lack of supporting documentation allows for the potential for misstatement of expenditures being charged to the major program for which the cost is unallowable. Questioned Costs: Actual and likely questioned costs estimated to be below the reporting threshold of $25,000. Based on the auditor?s review of pay rates, all employees were being paid a reasonable amount based on the their position and the auditor?s experience with similar entities. Repeat Finding: No. We believe this to be an isolated issue due to employee turnover. Recommendation: We recommend the District adhere to their internal control policies to ensure that the regulations contained in 2 CFR 200 are followed. Management?s Response: Management agrees with this finding. See Corrective Action Plan.

Finding 2022-008 Lack of Internal Control over Activities Allowed or Unallowed and Material Weakness Allowable Costs/Cost Principles Material Noncompliance Federal Agency: U.S. Department of Education Federal Program: School Safety National Activities and Native Youth Community Programs ALN: 84.184 and 84.299 Award Numbers: S299A170061, S299A18022, S299A180025, and S18G190154 Award Years: 2017, 2018, and 2019 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Allowable cost principles are defined in 2 CFR 200.400. Condition and Context: We select a sample of 25 expenditures transactions for ALN 84.184. The District did not provide supporting documentation for 4 of these transactions. The District also did not provide detailed payroll distribution reports to select samples from. We selected 6 payroll transactions for ALN 84.184 and 15 payroll transactions for ALN 84.299. The District did not provide the auditors with supporting documentation for any of the payroll transactions selected. Cause: Lack of internal control over transactions charged to the major programs. Effect: The lack of supporting documentation allows for the potential for misstatement of expenditures being charged to the major program for which the cost is unallowable. Questioned Costs: Actual and likely questioned costs estimated to be below the reporting threshold of $25,000. Based on the auditor?s review of pay rates, all employees were being paid a reasonable amount based on the their position and the auditor?s experience with similar entities. Repeat Finding: No. We believe this to be an isolated issue due to employee turnover. Recommendation: We recommend the District adhere to their internal control policies to ensure that the regulations contained in 2 CFR 200 are followed. Management?s Response: Management agrees with this finding. See Corrective Action Plan.

Finding 2022-008 Lack of Internal Control over Activities Allowed or Unallowed and Material Weakness Allowable Costs/Cost Principles Material Noncompliance Federal Agency: U.S. Department of Education Federal Program: School Safety National Activities and Native Youth Community Programs ALN: 84.184 and 84.299 Award Numbers: S299A170061, S299A18022, S299A180025, and S18G190154 Award Years: 2017, 2018, and 2019 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: Allowable cost principles are defined in 2 CFR 200.400. Condition and Context: We select a sample of 25 expenditures transactions for ALN 84.184. The District did not provide supporting documentation for 4 of these transactions. The District also did not provide detailed payroll distribution reports to select samples from. We selected 6 payroll transactions for ALN 84.184 and 15 payroll transactions for ALN 84.299. The District did not provide the auditors with supporting documentation for any of the payroll transactions selected. Cause: Lack of internal control over transactions charged to the major programs. Effect: The lack of supporting documentation allows for the potential for misstatement of expenditures being charged to the major program for which the cost is unallowable. Questioned Costs: Actual and likely questioned costs estimated to be below the reporting threshold of $25,000. Based on the auditor?s review of pay rates, all employees were being paid a reasonable amount based on the their position and the auditor?s experience with similar entities. Repeat Finding: No. We believe this to be an isolated issue due to employee turnover. Recommendation: We recommend the District adhere to their internal control policies to ensure that the regulations contained in 2 CFR 200 are followed. Management?s Response: Management agrees with this finding. See Corrective Action Plan.

FINDING 2022-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 20619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have effective internal controls in place to ensure that the required level of expenditures for non-public students for private school and homeschooled students were met. The School Corporation did not spend all of the required proportionate share for grant 20611-047-PN01. Additionally, the School Corporation did not spend any of the required proportionate share amount for grant 20619-047-PN01. For grant 20611-047-PN01, the amounts spent for one of the four teachers was not supported by timesheets. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 KANKAKEE VALLEY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 20619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have effective internal controls in place to ensure that the required level of expenditures for non-public students for private school and homeschooled students were met. The School Corporation did not spend all of the required proportionate share for grant 20611-047-PN01. Additionally, the School Corporation did not spend any of the required proportionate share amount for grant 20619-047-PN01. For grant 20611-047-PN01, the amounts spent for one of the four teachers was not supported by timesheets. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 KANKAKEE VALLEY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-047-PN01, 20619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have effective internal controls in place to ensure that the required level of expenditures for non-public students for private school and homeschooled students were met. The School Corporation did not spend all of the required proportionate share for grant 20611-047-PN01. Additionally, the School Corporation did not spend any of the required proportionate share amount for grant 20619-047-PN01. For grant 20611-047-PN01, the amounts spent for one of the four teachers was not supported by timesheets. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 KANKAKEE VALLEY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-008 Subject: Title I Grants to Local Educational Agencies - Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-008. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Officials of the School Corporation were unaware that the earmarking requirement for Parental Involvement was a mandatory spending requirement. Therefore, there were no internal controls in place related to this requirement nor was the required amounts spent for parental involvement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 37 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.207 (Uniform Guidance) states in part: "The Federal Awarding Agency or pass-through entity may impose additional specific award conditions as needed . . ." 2 CFR 200.208(b) (Revised Uniform Guidance) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, and Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-008 Subject: Title I Grants to Local Educational Agencies - Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2020-008. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Officials of the School Corporation were unaware that the earmarking requirement for Parental Involvement was a mandatory spending requirement. Therefore, there were no internal controls in place related to this requirement nor was the required amounts spent for parental involvement. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 37 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.400 states in part: ". . . (a) The non-Federal entity is responsible for the efficient and effective administration of the Federal award through the application of sound management practices. (b) The non-Federal entity assumes responsibility for administering Federal funds in a manner consistent with underlying agreements, program objectives, and the terms and conditions of the Federal award. . . ." 2 CFR 200.207 (Uniform Guidance) states in part: "The Federal Awarding Agency or pass-through entity may impose additional specific award conditions as needed . . ." 2 CFR 200.208(b) (Revised Uniform Guidance) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the earmarking requirements of the Matching, Level of Effort, and Earmarking compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.

Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: Child Nutrition Cluster ?School Nutrition Program ? Assistance Listing #10.555 and Summer Food Service Program ? Assistance Listing #10.559 2022-005 ? Significant Deficiency in Controls over Compliance and Compliance Finding: Administrative Requirements of Uniform Guidance ? Administrative Policies This is also a compliance finding, not just controls - UPDATED This is a repeat of prior year finding 2021-006 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management, procurement and compensation are in need of adoption and enhancement to meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: The Catholic Secondary Schools of the Diocese of Grand Rapids have limited written policies and procedures that are applicable to federal awards and address the direct and material compliance matters important to the major federal program. In addition, there are unique policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that are relevant to the Schools? federal programs. Recommendations: The Catholic Secondary Schools of the Diocese of Grand Rapids should adopt the following written policies and updates: ? Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ? Identification - Title of the award, CFDA number ? Complete disclosure of accurate and current financial results of each federal award ? Source and application of funds for federal award activity ? Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability access the records (?200.333 - ?200.337) ? Written procedure to implement cash management requirements (see below) ? Written procedures for determining the allowability of costs (see below) ? Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ? Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the Schools ensure compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ? Procurement Standards (2 CFR 200.317 ? 200.326) The Schools must have a written policy that promotes full and open vendor competition, conflict of interest policies should cover employees as well as the organization, and general purchase requirements with specific thresholds as set forth by the Uniform Guidance. There are five allowable procurement methods as described in ?200.320. ? Policy Guide (2 CFR 200.400) In summary, the Schools must have written policies that document the efficient and effective administration of federal awards through sound management practices. The Schools have the primary responsibility for employing whatever form of sound organization and management techniques may be necessary to assure proper and efficient administration of the federal awards. The accounting practices must be consistent with Uniform Guidance cost principles, support the accumulation of costs as required, and must provide for adequate documentation to support costs charged to the federal award. Views of Responsible Officials and Planned Corrective Actions: We concur with the findings of the auditors. We have developed a plan to address the findings, and are actively working to implement that plan. The corrective action plan is attached to this report.

FINDING 2022-007Subject: Title I Grants to Local Education Agencies - EarmarkingFederal Agency: Department of EducationFederal Program: Title I Grants to Local Educational AgenciesAssistance Listings Number: 84.010Federal Award Numbers and Years (or Other Identifying Numbers): FY19, FY 20Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Matching, Level of Effort, Earmarkingcompliance requirement.Officials of the School Corporation did not properly monitor the Homeless set-aside to ensureamounts were tracked for those students designated as homeless. For the Title I grant years FY19 andFY20, the entire Homeless set-aside of $1,632 and $550, respectively, was not spent. In addition, the setasideswere not carried forward for subsequent year expenses.The lack of internal controls and noncompliance were systemic issues throughout the audit period.INDIANA STATE BOARD OF ACCOUNTS27BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The Non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.400 states in part:"(a) The non-Federal entity is responsible for the efficient and effective administration of theFederal award through the application of sound management practices.(b) The non-Federal entity assumes responsibility for administering Federal funds in a mannerconsistent with underlying agreements, program objectives, and the terms and conditions ofthe Federal award. . . ."20 USC 6313(c)(3) states in part:"(A) In General. A local educational agency shall reserve such funds as are necessary underthis part, determined in accordance with subparagraphs (B) and (C), to provide servicescomparable to those provided to children in schools funded under this part to serve?(i) homeless children and youths, including providing educationally related supportservices to children in shelters and other locations where children may live;(ii) children in local institutions for neglected children; and(iii) if appropriate, children in local institutions for delinquent children, and neglected ordelinquent children in community day programs. . . .(C) Homeless children and youths. Funds reserved under subparagraph (A)(i) may be? . . .(ii) used to provide homeless children and youths with services not ordinarily provided toother students under this part, including providing?(I) funding for the liaison designated pursuant to section 11432(g)(1)(J)(ii) of title 42;and(II) transportation pursuant to section 11432(g)(1)(J)(iii) of such title."CauseManagement had not established an effective system of internal controls that would have ensuredcompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.INDIANA STATE BOARD OF ACCOUNTS28BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls related tothe grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

FINDING 2022-007Subject: Title I Grants to Local Education Agencies - EarmarkingFederal Agency: Department of EducationFederal Program: Title I Grants to Local Educational AgenciesAssistance Listings Number: 84.010Federal Award Numbers and Years (or Other Identifying Numbers): FY19, FY 20Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Matching, Level of Effort, EarmarkingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Matching, Level of Effort, Earmarkingcompliance requirement.Officials of the School Corporation did not properly monitor the Homeless set-aside to ensureamounts were tracked for those students designated as homeless. For the Title I grant years FY19 andFY20, the entire Homeless set-aside of $1,632 and $550, respectively, was not spent. In addition, the setasideswere not carried forward for subsequent year expenses.The lack of internal controls and noncompliance were systemic issues throughout the audit period.INDIANA STATE BOARD OF ACCOUNTS27BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Criteria2 CFR 200.303 states in part:"The Non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.400 states in part:"(a) The non-Federal entity is responsible for the efficient and effective administration of theFederal award through the application of sound management practices.(b) The non-Federal entity assumes responsibility for administering Federal funds in a mannerconsistent with underlying agreements, program objectives, and the terms and conditions ofthe Federal award. . . ."20 USC 6313(c)(3) states in part:"(A) In General. A local educational agency shall reserve such funds as are necessary underthis part, determined in accordance with subparagraphs (B) and (C), to provide servicescomparable to those provided to children in schools funded under this part to serve?(i) homeless children and youths, including providing educationally related supportservices to children in shelters and other locations where children may live;(ii) children in local institutions for neglected children; and(iii) if appropriate, children in local institutions for delinquent children, and neglected ordelinquent children in community day programs. . . .(C) Homeless children and youths. Funds reserved under subparagraph (A)(i) may be? . . .(ii) used to provide homeless children and youths with services not ordinarily provided toother students under this part, including providing?(I) funding for the liaison designated pursuant to section 11432(g)(1)(J)(ii) of title 42;and(II) transportation pursuant to section 11432(g)(1)(J)(iii) of such title."CauseManagement had not established an effective system of internal controls that would have ensuredcompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.INDIANA STATE BOARD OF ACCOUNTS28BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective system of internal controls enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls related tothe grant agreement and the Matching, Level of Effort, Earmarking compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Finding 2021-003: Material Weakness and Questioned Cost – Grant Claim Support Federal grantor: Department of Commerce Condition: The Chamber’s expenditure detail for the grant funded projects do not support the amounts billed to the Department of Commerce. The amounts billed were more than the general ledger detail supported. Criteria: A reconciliation of grant project expenses to the grant revenue billed should be performed. The supporting documentation of any reconciling items should be maintained with the grant bills. Also, 2 CFR 200.400 states that accounting practices of the entity be consistent with cost principals required under the CFR and support the accumulation of costs and provide adequate documentation to support costs charged to the Federal award. Cause: The Chamber billed costs to the grant that were not allocated in the accounting system to that grant and a reconciliation was not performed comparing the grant billings to the expense detail. Effect: The expenses billed to the grant may not be correct. Our reconciliation of these expenses disclosed an overbilling to the grant of approximately $2,500. Recommendation: The Chamber needs to ensure that expenses to be reimbursed by federal grant funds are recorded in the class code in the accounting system for that grant so that federal grant revenue in the accounting system match the expenses allocated to that grant. The Chamber needs to include in their year-end reconciliations a comparison of grant revenue and expense and ensure they match or can be reconciled. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.

Finding 2021-004: Significant Deficiency – Grant Claim Support Federal grantor: Department of Commerce Condition: The allocation of payroll costs to programs are done manually using spreadsheets instead of done based on entity-wide timesheets. Criteria: Under 2 CFR 200.400, direct cost allocation principles state that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Further, a cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. Costs are required to be adequately documented. Cause: The Chamber is not able to readily determine the amount of payroll costs billable to the grants. Effect: The approach of manually allocating payroll costs to grant projects leaves room for error, and makes it difficult to determine that costs are not being reimbursed by more than one source. Recommendation: The Chamber needs to prepare time studies or require employees to prepare timesheets on an automated system to support the payroll costs allocated to programs. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.

Finding 2021-003: Material Weakness and Questioned Cost – Grant Claim Support Federal grantor: Department of Commerce Condition: The Chamber’s expenditure detail for the grant funded projects do not support the amounts billed to the Department of Commerce. The amounts billed were more than the general ledger detail supported. Criteria: A reconciliation of grant project expenses to the grant revenue billed should be performed. The supporting documentation of any reconciling items should be maintained with the grant bills. Also, 2 CFR 200.400 states that accounting practices of the entity be consistent with cost principals required under the CFR and support the accumulation of costs and provide adequate documentation to support costs charged to the Federal award. Cause: The Chamber billed costs to the grant that were not allocated in the accounting system to that grant and a reconciliation was not performed comparing the grant billings to the expense detail. Effect: The expenses billed to the grant may not be correct. Our reconciliation of these expenses disclosed an overbilling to the grant of approximately $2,500. Recommendation: The Chamber needs to ensure that expenses to be reimbursed by federal grant funds are recorded in the class code in the accounting system for that grant so that federal grant revenue in the accounting system match the expenses allocated to that grant. The Chamber needs to include in their year-end reconciliations a comparison of grant revenue and expense and ensure they match or can be reconciled. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.

Finding 2021-004: Significant Deficiency – Grant Claim Support Federal grantor: Department of Commerce Condition: The allocation of payroll costs to programs are done manually using spreadsheets instead of done based on entity-wide timesheets. Criteria: Under 2 CFR 200.400, direct cost allocation principles state that if a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Further, a cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. Costs are required to be adequately documented. Cause: The Chamber is not able to readily determine the amount of payroll costs billable to the grants. Effect: The approach of manually allocating payroll costs to grant projects leaves room for error, and makes it difficult to determine that costs are not being reimbursed by more than one source. Recommendation: The Chamber needs to prepare time studies or require employees to prepare timesheets on an automated system to support the payroll costs allocated to programs. Management’s Response: Management’s response to the finding is discussed in the Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.

Finding 2021-004: Material Weakness Due to Unsupported Administration and Program Operations Costs Federal Agency: U.S. Department of Treasury Program Title: Emergency Rental Assistance Program and Corona Virus Relief Fund Assistance Listing Numbers (ALN): 21.023 and 21.019 Federal Award Years: Year ended December 31, 2023 Pass-through Grantor and identifying numbers: Pierce County; SC-108112, SC-108282, SC-108719, SC- 108080 Criteria: Charges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles. Specifically CFR 200.400(d) indicates the Organization must support the accumulation of costs and provide for adequate documentation to support costs charged to the Federal award. Condition and Context: Administration and program operation costs charged to the award for the period ended December 31, 2021 lacked supporting documentation to verify whether there were equivalent administrative and program operation expenses incurred by the Organization. All budgets approved by the Pass-through Grantor allowed for such costs to be reimbursed by the award as long as adequate documentation of how the costs were determined was retained. Since the organization did not retain any such documentation, there is no way of knowing if a portion or all of those administration or program operation costs related to actual activities that were performed related to these programs. The Organization most certainly did incur administration and program operation costs that were legitimate to be remitted to the award. However, with no controls in place to ensure that these costs were appropriately accumulated and documented, the amounts reimbursed by the programs might not be appropriate. During our audit, we were able to fully quantify the full amount of administration and program operations costs that were inappropriately supported through discussions with management of the Organization and reviewing the reimbursement requests that were submitted to the Pass-through Grantor. The amounts included in the questioned costs below is the entire amount of such costs that were charged to the program during the year ended December 31, 2021. Cause: Helping Hand House did not have processes and controls in place to ensure that documentation to ensure that administrative and program operation costs that were charged to the program were appropriately documented. Effect: There is the potential that the Pass-through grantor may require a repayment of a portion or all of the program and administrative costs that were paid for by the program. As such, a loss contingency disclosure has been included in the notes to the financial statements to indicate that there is the potential that the Pass-through Grantor may require some of these amounts to be repaid. This also is the reason for the qualified opinion in the Report On Compliance for Each Major Federal Program. Known Questioned Costs for ALN 21.023: $329,572 Known Questioned Costs for ALN 21.019: $164,757 Repeat Finding: Not applicable. Recommendation: We recommend that Helping Hand House develop and document procedures and controls for how administrative and program operation costs will be allocated to the federal awards. This information should be retained so that it can be made available at the request of the Pass-through Grantor, the auditor or other relevant parties. Views of Responsible Official: See Corrective Action Plan.