Corrective Action Plans

The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.

The organization acknowledges that time and effort procedures were not consistently followed throughout FY24. The organization has implemented a new system of reporting designed to capture time and effort of all employees charged to government grant and contracts, as well as other grants and contracts awarded to the agency from the philanthropic community. Additionally, along with the timesheet, the agency now requires that an attestation statement is prepared quarterly by Program Managers and Directors for all employees charged to grants to attest to the actual amount of time spent and allocated to the grants. The organization has expanded administrative oversite of the finance department and financial data and has hired a Finance Director who has spent a considerable amount of time training staff and managers regarding their allocations and their obligations to track their time. The Finance Director has trained our expanded finance team on ensuring that accounting policies and procedures are strictly adhered to and that GAAP is uniformly applied to all financial data of the agency.

The organization acknowledges that unallowable rent costs were claimed and payment received under government grants and contracts resulting in overstating revenues for FY24, and that adjustments were necessary to the financial statements to correct the resulting deficiencies. As indicated, however, this overstating was due to the unique situation that existed as a result of the landlord’s breaking the organization’s lease, suddenly and without notice. Rent costs were claimed for as long as the organization was liable for the rent. After the liability was forgiven by the landlord, rent costs were returned to the funders.

Supporting Documentation of Payroll Costs Recommendation: Policies and procedures over the processing of payroll transactions should include proper review and approval of timesheets to ensure hours match the hours per payroll register and correct hours are charged to the grant. There is no disagreement with the audit finding. Action planned/taken in response to finding: High quality accounting personnel will ensure hours match the hours per payroll register and correct hours are charged to the grant. Name(s) of the contact person(s) responsible for corrective action: Mary Ann Mahon Huels, President and CEO Planned completion date for corrective action plan: Immediately

Audit Finding 2024-002 Reference: Expenses charged to federal awards outside the designated period of performance. (2 out of 40 sampled) ________________________________________1. Issue Summary The audit identified two instances where expenses were charged to a federal grant outside the approved period of performance. These expenses were tied to invoices that began within the period of performance and a portion extended beyond the performance period. The root cause was insufficient review of transaction timing and lack of controls to ensure compliance with Uniform Guidance requirements. ________________________________________ 2. Root Cause Analysis Lack of a formalized review process for validating transaction that span extended period dates that may extend past grant period of performance. ________________________________________ 3. Corrective Actions A. Implement a Formal Expense Review Protocol • Develop and document a standard operating procedure (SOP) for reviewing all grant-related expenses. • Require validation of invoice service dates and delivery dates before posting to federal awards • Include a checklist for SPF accountants to confirm alignment with the period of performance. B. Staff Training and Awareness • Conduct mandatory training sessions for all staff involved in grant accounting and expense processing. • Include guidance on: o Allowable costs under 2 CFR Part 200 o Period of performance compliance o Documentation standards ________________________________________ 4. Responsible Parties • Finance Director: Oversight and implementation of corrective actions • Sponsored Projects Finance Team: Execution of SOP and transaction reviews ________________________________________ 5. Timeline Action Item Target Completion Date Policy Development Already implemented Staff Training Completed initial training, additional will be ongoing

Audit Finding 2024-001 Reference: Over-allocation of payroll expenditures to grant-funded programs (2 instances out of 40 sampled) ________________________________________ 1. Issue Summary During the audit of allowable payroll costs, two instances of over-allocation to grant-funded programs were identified. These occurred early in the fiscal year due to imprecise monthly allocation methods and insufficient review prior to posting. ________________________________________ 2. Root Cause Analysis • Use of a monthly allocation methodology lacking precision. • Insufficient review and approval of payroll allocations before posting. • Lack of real-time substantiation of salary distributions with actual time worked. ________________________________________ 3. Corrective Actions • Already implemented in the second half of the fiscal year, continue using the granular allocation method based on actual pay periods; including ongoing monitoring. • Implement a mandatory review of payroll allocations by project staff with support from SP&F accountants • Require timesheets or effort certifications and manager’s approval for personnel charged to federal awards. • Update internal payroll allocation policies to reflect new methodology and controls. • Conduct training sessions for finance and staff assigned to grants on revised payroll allocation procedures and compliance requirements. ________________________________________ 4. Responsible Parties Sponsored Projects Finance Team: Transaction reviews Finance Director: Oversight and implementation of corrective actions ________________________________________ 5. Timeline Action Item Target Completion Date Allocation Actual Pay Already implemented Review of Allocations Already implemented Timesheet/Policy Development Already implemented Staff Training Completed initial training, additional will be ongoing

Finding 2024-003: Activiites Allowed or Unallowed & Allowable Costs/Cost Principles & Period of Performance (Clean Energy Demonstrations - ALN 81.255). Contact Person: Manny Citron, Chief Operating Officer. Recommendation: MACH2 should establish an internal control policy to ensure transactions are reviewed and approved prior to being charged to the grant and the approval should be documented for each transaction. Action: MACH2 has created and implemented written policies prior to execution of cooperative agreement regarding the review and approval of grant expenditures. These policies ensure transactions are reviewed with multiple approvals and for accuracy, allowability, allocability, and eligibility prior to being submitted for reimbursement. In addition, MACH2's policies are designed to demonstrate compliance with 2 CFR 200 by esbalishing internal controls that maintain documenation of approvals and ensuring segregation of duties so that no single individual has control of processing of transactions. Date of Completion: October 31, 2025.

Condition: The Town’s procurement files did not contain documentation regarding competitive procurement procedures for one contract. The Town, through the Raynham Center Water District, awarded a contract for final design services for two water treatment plants to a vendor that had previously provided preliminary evaluations for the plants, without performing competitive procurement procedures. Corrective Action Planned: The Town will implement policies and procedures to ensure a competitive procurement is performed in accordance with federal procurement guidelines for all applicable contracts paid with federal funds. Anticipated Completion Date: August 2025 Contact: Christopher P. Laviolette, CPA, Finance Director/Town Accountant

Review AP policies, train AP personnel, and require double approval before using grant funds

We are working on policies and procedures to match up to the DAF sections. The procedures and policies are based on the NHED Fact Sheets.

Management will reimburse the County for unallowable costs. Management will also strengthen internal controls over cost allowability, including staff training, implementation of formal pre-approval process, and a documented review checklist prior to reimbursement submission related to federal programs to ensure compliance.

Finding 2024-004 - Material Weakness in Internal Control over Compliance and Material Noncompliance (Qualified Opinion) - Inadequate Tracking of Expenditures and Retention of Documentation: Activities Allowed or Unallowed: Allowable Costs/Cost Principles and Reporting (A/B/L) for Assistance Listing Number 19.510 and 93.567 Criteria: The Code of Federal Regulations (CFR) Section 200.510(b) states in part, “The auditee must also prepare a schedule of federal expenditures for the period covered by the auditee’s consolidated financial statements which must include the total Federal awards expended as determined in accordance with 200.502.” Also, in accordance with CFR Section 200.302(b) - Financial Management, the auditees financial management system must provide 1) identification of all federal awards received and expended; 2) accurate, current, and complete disclosure of the financial results of each federal award or program; 3) records that identify adequately the source and application of funds for federally‐funded activities; 4) effective control over, and accountability for, all funds, property, and other assets; 5) comparison of expenditures with budget amounts for each Federal award; 6) written procedures to implement the requirements of section 200.305 and; 7) written procedures for determining the allowability of costs in accordance with Subpart E and the terms and conditions of the Federal award. Recipients of federal awards must submit accurate, complete and timely financial and performance reports. The Organization should have internal controls designed to ensure compliance with those provisions. The Organization should retain sufficient documentation such as invoice and allocation support for expenditures to retain documentation for audit purposes. Condition: During detail testing of expenditures, it was noted that the Organization did not maintain adequate documentation to support how certain costs were allocated to the federal program. Several transactions lacked sufficient detail, such as invoice or expense reimbursement form. Several expenditures selected for testing did not obtain sufficient approval by an individual at the Organization. There was one instance of employee compensation being processed at an approved pay rate and the Center could not provide any supporting documentation such as an offer letter, to substantiate the rate paid. It was noted that quarterly reports provided to the federal program were not reviewed by an individual at the Organization prior to submission to ensure accurate report of expenditures. 2 of the 8 monthly reports sampled were not submitted timely to the grantor. Cause: The Organization does not have an adequate system in place to ensure quarterly reports have sufficient supporting documentation, proper approval/review, and accurate reporting prior to submission. Responsibilities for expenditure tracking were not clearly assigned, and there was no formal review process in place. The Organization is not following their Document Retention Policy. Effect: The effect of this condition increases the possibility that quarterly financial reports are misstated or inaccurate and increase the risk of noncompliance with federal requirements. The effect of this condition also increases the risk that expenditures are unallowable per the grant, federal regulations, or cost principles due to the insufficient support of proper approval retained. Questioned costs: None Repeat Finding: Yes - 2023-003 Recommendation: Policies and procedures should be in place to ensure quarterly financial reports are properly supported, accurately reported, and adequately approved and reviewed. A formal review process should be established to ensure compliance. The Organization should follow the Document Retention Policy that was put in place and required by law and submit the required reporting documentation timely to the grantor to ensure compliance. Management Response: There is no disagreement with the audit finding. Management has taken steps to address these deficiencies in fiscal year 2025 including but not limited to: the implementation of a new accounting system that includes document retention and review/sign off logs, the engagement of a third-party CPA firm to provide client advisory and accounting services and the review and updating of accounting policies and procedures for best practices. Responsible Person for Corrective Action Plan: Marc Hall, Director of Operations Implementation Date for Corrective Action Plan: Fiscal year 2025

As noted in the findings, turnover issues and documentation within the department were primary causes for the issues raised. The hiring of qualified staff properly trained should avoid this error going forward. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

As most of the findings were related to turnover and the inability to sufficiently document approvals or processes. Going forward, care should be taken to document necessary approvals in care of the program and academic management. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

Management acknowledges the lack of proper certification documentation for one teacher funded by Title I federal funds. During fiscal year 2024, the school experienced significant turnover in administrative staff, which contributed to gaps in documentation and compliance oversight. Since then, the administrative team has stabilized and is now operating more effectively. Additionally, the new school leadership proactively identified weaknesses in the grants management process and replaced the previous team with a much more experienced one. This new team has significantly improved oversight and strengthened compliance with federal program requirements, ensuring that all personnel funded through federal grants meet the necessary certification and eligibility standards.

Management acknowledges that the required single audit report was not filed within the timeframe specified in 2 CFR Part 200, Subpart F, § 200.512. Fiscal Year 2024 was the first year our organization exceeded the federal expenditure threshold that triggers a single audit requirement. It was our understanding that there was a change to the threshold from $750,000 to $1,000,000. Unfortunately, management misunderstood effective date was for fiscal year 2024 and not 2025. As a result, we incorrectly concluded that a single audit was not required for that year. Going forward, a new internal control has been established requiring annual verification and documentation of total federal expenditures and the applicability of the single audit threshold. The Finance Designee will complete this verification, which will then be formally reviewed and approved by the Chief Financial Officer. Additionally, management will initiate audit planning discussions with external auditors earlier in the fiscal year to confirm whether a single audit is required, ensuring timely preparation and compliance.

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Quincy, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17ᵗʰ Floor Boston, MA 02109 Audit period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Financial Statement Finding Finding 2024-001: Certain Department Expenditures Exceeding Appropriated Amounts – General Fund – Significant Deficiency Condition: During 2024, it was noted that expenditures in the public safety and education functions exceeded the amounts appropriated by the City Council for the fiscal year. Criteria: Massachusetts general law prohibits the City from incurring liabilities in excess of appropriations in each department with certain specific exceptions, such as snow and ice removal costs, state and county charges, and debt service. Prudent budgetary control and monitoring are essential to ensure compliance with such requirements. Cause: The overspending of these appropriations occurred due to an inadequate internal control system to ensure timely budget amendments. Effect: Overspending appropriations in the General Fund constitutes noncompliance with state law and exposes the City to potential fiscal consequences, as the state may require the City to raise such deficits in the subsequent fiscal year. It may also indicate a weakness in the City's internal controls over budgetary compliance. Recommendation: We recommend that City management strengthen internal controls over budgetary compliance. Management should strengthen its’ procedures throughout the year to monitor budget-to-actual expenditures and ensure timely action, such as requesting formal budget amendments when actual expenditures approach or exceed authorized appropriations. Views of Responsible Officials: The Municipal Finance Office will be implementing procedures to ensure that the Municipal Finance Office and relevant department heads document reviews of budget to actual reports monthly throughout the year, with increased review intervals during June. The purpose of this increased monitoring is to ensure that potential budgetary appropriation deficits are identified in a timelier manner that will allow for any necessary budgetary amendments to be approved by the City Council. Finding 2024-002: Information Technology Controls in Financial Statements – Significant Deficiency Condition: During 2024, we noted the following deficiencies relating to information technology controls in the financial statement reporting process: • User Access Mirroring: When new users are provisioned in the accounting system, access rights are often “mirrored” from existing users without sufficient review of job responsibilities. This practice results in users receiving access to system functions beyond what is necessary for their roles and may compromise segregation of duties. • Privileged Access: A review of privileged user listings indicated access accounts with no exclusionary parameters. • Inadequate Controls Over System Upgrades: When implementing accounting system upgrades, controls over change management including testing, documentation, and approval, were not adequately designed or consistently applied. Instances were noted where upgrades were implemented without thorough pre-deployment testing and formal approval from finance or IT management. Criteria: Best practices and standards for internal control require: • Role-based access provisioning aligned with users’ responsibilities and effective segregation of duties. • The use of exclusionary parameters enhances the ability to monitor system access for unauthorized access. • Robust change management controls over system upgrades, including testing, documentation, and management approval, to ensure system integrity and minimize the risk of errors or unauthorized changes impacting financial reporting. Cause: These deficiencies appear to result from a lack of formalized policies and procedures for user access provisioning and for managing and documenting accounting system upgrades. Effect: The deficiencies increase the risk of: • Unauthorized access or inappropriate transactions due to excessive or incompatible user rights, undermining segregation of duties and accountability. • Errors, omissions, or unauthorized changes introduced during system upgrades, potentially affecting the integrity and accuracy of financial data and financial statement preparation. Recommendation: We recommend that City management: • Implement procedures to provision user access based on individual roles and responsibilities, with documented review and approval to ensure segregation of duties is maintained. This should be evidenced by written approval that is approved by Municipal Finance and Information Technology office. • Enhance the current process of implementing accounting system upgrades, including requirements for comprehensive pre-deployment testing, clear documentation, and explicit written approval from the Municipal Finance Office and the Information Technology office, prior to going “live” with the upgrade. • Periodically review system access and upgrade processes to ensure ongoing compliance with internal control standards. Views of Responsible Officials: The City will keep these recommendations in mind as it works to upgrade its already existing best practice IT control environment. Finding and Questioned Costs – Major Federal Program Audit Criteria or Specific Requirement: Uniform Guidance section 2 CFR § 200.430(g) requires non- Federal entities to maintain records that accurately reflect the work performed by employees whose salaries are charged, in whole or in part, to Federal awards. For employees working on a single Federal program, semi-annual certifications are required to document time and effort. Condition and Context: During testing of 40 payroll transactions for employees charged to the Special Education program, the City was unable to provide semi-annual certifications supporting that salaries and wages were properly allocated to the grant. Cause: The City did not have adequate procedures in place to ensure that required time and effort certifications were retained and readily available for payroll charged to Federal awards. Effect or Potential Effect: Failure to maintain required time and effort documentation resulted in the questioned costs documented below. Questioned costs are reported as follows: AL Number: 84.027 Name of Federal Program or Cluster: Special Education Cluster Questioned Costs: $2,572,675 Recommendation: We recommend the City establish and implement procedures to ensure that semiannual certifications are completed, maintained, and reviewed for all personnel whose salaries are charged to Federal awards. Views of Responsible Officials: This is a questioned cost due to the School Department not having completed certain administrative paperwork, required by grant regulations. We have implemented procedures during FY2025 to address this matter. The required paperwork will be retained on file going forward.

Finding 2024-004: Internal Control over Compliance Type of finding: Internal Control (material weakness) and Compliance (material noncompliance) Recommendation: The County should strengthen its internal controls over year-end financial close and reporting with adopted policies and procedures to ensure compliance with the Report submission portion of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements section. Action Taken: This finding is very similar to 2024-002. So, the action taken will be the same as noted for that finding and is as follows. The new accountants are not anticipating any issues with meeting the deadline of June 30, 2026 for the 2025 audit. As they have been busy implementing the new processes that are mentioned in the action taken plan for finding 2024-001. These new processes will ensure that they are able to meet any audit requirements for the 2025 audit in a timely manner. In addition, they are already making plans to start submitting reports, etc. to the auditor immediately beginning in the first quarter of 2026. Another thing that will help with the completion of the audit by deadline is that the accounting office and Treasurer's office have developed a good relationship and have a great line of communication, which helps in getting tasks completed on time. If there are questions regarding this plan, please call the party responsible listed below. Sincerely yours, Tressesa Martinez County Administrator Conejos County, Colorado

Walla Walla County is taking significant steps to address the recent audit finding regarding inadequate internal controls for compliance with federal requirements. Development of a New Policy To rectify this issue, the county is committed to formulating a new policy specifically tailored to meet federal standards. This development process is already in motion, with the expected completion date set for December 2025. Enhancing Internal Controls We believe that the new policy will significantly improve our internal controls and ensure full compliance with federal mandates. Training Initiatives Additionally, we will seek training opportunities to increase the knowledge of all staff regarding federal programs and compliance requirements, ensuring adherence to these programs and grants.

Grantee Response and Corrective Action Plan: AVLF concurs with the recommendation. The Organization will take the following corrective actions: 1. Remit corrected timesheets to the Agency for information purposes. 2. Revise the organization’s policy to include review and reconciliation of SER’s and timesheets prior to submission to the Agency. Responsible Parties: Jason Levister, Controller Date to be Completed: October 2025

● The Organization will develop a policy and procedures that require documentation of subrecipient monitoring for each subrecipient. ● The Organization will redesign the subrecipient contract template to include the federal award identification number and amount of federal funds awarded to each subrecipient. ● The Finance Director will distribute the policies and procedures along with the new contract template to all staff that manage grants. ● The Finance Director will train the staff on the new policies and procedures.

Corrective Action Plan Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: In response to the finding, management will reinforce its expenditure approval policy by requiring all purchases and payments to have complete documentation and pre-approval from the appropriate level of management. Will perform quarterly internal audits to ensure ongoing compliance. Official Responsible for Ensuring CAP: Paul Walker, Chief Executive Officer Planned Completion Date for CAP: Immediately Plan to Monitor Completion of CAP: The CEO will convene quarterly meetings with the Finance and Compliance departments to review sampled federal transactions for proper documentation and approval. A compliance checklist will be completed and retained for monitoring.

Management disagrees with the following A) Management determined the expenditures charged to the 2021-#3 project MSOC Security Sustainment Costs, for camera, installation and project management were clearly related to the Investment justification which requested sustainment and upgrade to the existing MSOC the IJ states : “Investment provides maintenance and upgrades of software/hardware (I.e. servers/workstations), video surveillance management systems, operating systems, cameras systems, access control and communication systems for Plaquemines Port Harbor and Terminal District B) Management determined the questioned cost charged to the 2023-#3 project GIS for the cameras and the conference room were supported with the investment justification however management agrees the invoices for Survey totaling $95,900 should not have been changed to the grant. C) Management determined the expenditures charged to the 2023-#4 project Cybersecurity Network and IT: For Datto Backup, which is the name of the program, and cyber security training are valid expenses and align with the investment justification Management will ensure the following processes are added to the financial management policies and procedures over federal and state funds • The District will establish formal procedures requiring that all PSGP expenditures be cross-checked against the approved Investment Justification (IJ) and verified for compliance with the grant’s period of performance prior to payment. No disbursement of federal funds will occur unless documentation demonstrates that the expenditure directly aligns with the approved grant scope and timing. • This documentation will be required within the system in order to process payments to the vendor. • The District will consult with FEMA to assess the allowability of identified questioned costs. Management will follow FEMA’s guidance to resolve any discrepancies and ensure that all expenditures meet federal standards. • Mandatory training sessions are being scheduled for staff involved in grant administration and financial management. These sessions will cover Uniform Guidance requirements, documentation standards, and procedures for verifying expenditure eligibility under PSGP. These actions reflect the District’s commitment to regulatory compliance, fiscal responsibility, and continuous improvement in federal grant management practices.

The Organization will revisit the internal control process around invoice submissions and reimbursement request review. The Organization has since hired an outsourced accountant to assist with record keeping and assisting with ensuring compliance with Uniform Guidance. The Organization strives to remain compliant with Uniform Guidance in all respects to present both accurate and transparent records. If the Missouri Department of Social Services or the U.S. Department of the Treasury have questions regarding this plan, please call Jennifer Gadsky, MSW, LCSW, Executive Director, at (314)-938-4414.

Cause: Costs charged on the vendor invoice were not separated between allowable activity, broadband infrastructure development, and unallowable activity, electrical infrastructure development. Corrective Action Plan: “The corrective action has already been taken prior to audit completion. The costs related to unallowable activities have been reimbursed to the grant in the form of an offset against May 2025 draw to correct the error. All project expenditures incurred to date were reviewed to confirm there were no additional unallowable charges. Training was provided to contractors and subcontractors involved with the project to ensure a thorough understanding of the importance of maintaining separate accounting records for grant and non-grant projects. Furthermore, all personnel involved in grant administration, including project managers and finance staff, are required to attend training on federal grant compliance. Going forward, project and support teams will perform a more comprehensive review of project invoices and billing details as well as monitor project’s spend variances more closely to ensure grant compliance.”