Corrective Action Plans

Finding 2022-003 United States Department of Health and Human Services Pass-through from North Carolina Department of Health and Human Services Program Name: Block Grants for Prevention and Treatment of Substance Abuse Federal Assistance Listing Number - 93.959 Significant Deficiency in Internal Control over Compliance and Nonmaterial Noncompliance - Allowable Activities/Costs Responsible Individuals: Thom Elmore, Executive Director Finding Summary: Our audit procedures noted multiple instances in which costs were included in the grant reimbursement reports that were unallowed per the terms of the grant agreement and relevant federal and state compliance guidance. These findings included the inclusion of sales tax expenses that could be legally recouped by means of refunds, inadequate documentation supporting the current pay rate for an employee whose wages were included in the award reimbursement requests, and reported indirect costs that exceeded the maximum allowable indirect cost rate per the terms of the award. The total questioned costs related to these findings were not material to program compliance. Corrective Action Plan: The Organization has developed appropriate controls over the review and approval of allowable costs; however, the Organization will review and strengthen these control activities by providing a more thorough examination of expenditure supporting documentation by an individual that is not responsible for preparing the federal award reimbursement requests. Additionally, we will review and strengthen our internal control activities over personnel pay rate changes by requiring independent verification that all pay rate changes implemented are supported by current documentation in the respective employees' personnel file. Anticipated Completion Date: Ongoing.

U.S. Department of Education 2022-002 21st Century Community Learning Centers ? Assistance Listing No. 84.287C Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review amounts charged to the grant prior to submitting for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new Chief Financial Officer was hired in March 2022 with appropriate expertise to evaluate financial reporting processes and controls. Additional controls over the preparation of financial statements to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP have been implemented.. Name(s) of the contact person(s) responsible for corrective action: Jerri Kautsky Planned completion date for corrective action plan: completed as of date of audit report, December 8, 2022. If the U.S. Department of Education has questions regarding this plan, please call Jerri Kautsky, CFO, at 239-255-7223.

Finding 2022-002 The Center?s use of spreadsheets for labor allocations did not provide a documented system of internal control that could be used to test changes to allocation made during the year. Corrective Actions Taken or Planned: Management concurs with this finding. On March 1, 2023, Carole Robertson Center for Learning transitioned tracking of labor costs to our human resource information system, Paycor. This has been a work-in-progress which began in the fall of 2021. The result has been accomplished with diligence, attention to detail, efficiency and accuracy during a period a significant growth. Each pay period, Paycor produces a Job Costing Report that supports the reimbursement process for labor costs. Further, the content of the Job Costing Report seamlessly exports these costs to the general ledger for each pay period. A formal approval process will be established to connect the flow of documentation from budgeting, to actual costs incurred, to the reimbursement from funders so that verification of each element (grant budget development, payroll, cost allocations, general ledger entries, and reimbursement requests) will match/reconcile without requiring recalculation. The contact person is Peg Heslinga, Chief Financial Officer. SAGE Intacct accounting software will be implemented with a planned go-live date of July 1, 2023. The contact person is Peg Heslinga, Chief Financial Officer. Our Accounting Policies and Procedures will be reviewed by November 1, 2023, and revised to reflect accounting policies that have been modified since the previous version was approved in September 2022. Going forward, these policies will be reviewed annually for needed revisions. The contact person is Peg Heslinga, Chief Financial Officer. The Controller, the Director of Accounting, the Director of Contracts Management, and the Contracts Manager will attend Uniform Guidance training, and all positions within the Finance Department will be reviewed to determine additional training and education needs. Implementation is planned for completion by September 30, 2023. The contact person is Peg Heslinga, Chief Financial Officer.

Finding 2022-002: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics Federal Financial Assistance Listing/CFDA Number: 93.697 Finding Summary: The Medical Center?s listing of expenses claimed under the Testing and Mitigation for Rural Health Clinics program as an allowable cost had more expenses than funds received. Some of these excess funds related to a different period and would have been reported on the Schedule in a different year. This should have been caught with an effective secondary review of expenses. Responsible Individuals: Nathan Pickel, Chief Financial Officer Corrective Action Plan: Management agrees with the finding. Controls will be put into place for a more thorough review of the expense detail to ensure expenditures being claimed pertain to the year in which they were incurred. For the current year, the expense detail was ran by accounting date as opposed to service date. Anticipated Completion Date: June 30, 2023

SIGNIFICANT DEFICIENCY Finding 2022 ? 001 Activities Allowed, Allowable Costs Name of contact person: Kirby Nickerson, CFO Corrective Action Plan: Management plans to review the segregation of duties in order to provide reasonable assurance that transactions are handled appropriately. This will include a process review of expenditure approval prior to payment and approval of the Personal Action Forms used to make payroll changes. If changes are needed to the process to provide the reasonable assurance that transactions are handled appropriately, management will collaboratively work with the operations team to revise the procedures as necessary. Lastly, training for managers and supervisors will be provided on the procedures to ensure the proper implementation of the updated process. Proposed Completion Date: Management will implement the above plan by the end of April 2023.

U. S. Department of Housing and Urban Development (Pass-through from Virginia Office of Community Planning and Development) Assistance Listing #14.267 Finding: 2022-003 Known Questioned Costs for a Federal Program Not Audited as a Major Program Criteria: In accordance with 2 CFR 200.516(a)(4) known questioned costs that are greater than $25,000 for a program that is not audited as a major program must be reported as an audit finding in the federal awards section of the schedule of findings and questioned costs. In September 2022, the U. S. Department of Housing and Urban Development, identified $1,463 of unallowed expenditures and a deficit of $27,464 in the required cash match under the Continuum of Care program for the year ended December 31, 2021, as a result of monitoring. Rapid Rehousing Requirements: Criteria: 24 CFR 578.51; 24 CFR 578.57 Condition: The Federal awarding agency has determined, in accordance with 24 CFR 578.51; 24 CFR 578.57; $1,463 of allowable HMIS expenses were not documented and that in accordance with 2 CFR 200.1; 2 CFR 200.103(a)(11); 2 CFR 200.306; 24 CFR 578.73 the grantee failed to match $27,464 on its Continuum of Care rapid rehousing project. Corrective Action Plan: The CFO will ensure that the HMIS expenses are being captured in financial documents be setting up a new account code in the financial software. Staff members that have HMIS hours will also record those hours separately on their timesheets each pay period. NRCA will be submitting copies of timesheets which record data entry by line item as further documentation of the HMIS expenses submitted in answers to the monitoring report. While NRCA respects the position of the Department of HUD, NRCA also believes management followed the grant agreement as submitted. NRCA sees resolution to this matter with the Department of HUD and is currently seeking counsel to ensure this resolution in an acceptable and appropriate manner. Persons Responsible: Michelle Cox, Chief Financial Officer and Krystal Thompson, Chief Executive Officer Timing for Implementation: Immediate

Finding 2022-003 Federal Transit Cluster - SEFA Management?s or Department?s Response: Management agrees. Views of Responsible Officials and Corrective Action: SCRRA will document the process to review the SEFA from prior year. Compare the SEFA to the final Single Audit Report to ensure the ending balances tie back to the Single Audit Report, before starting the current year?s SEFA. Name of Responsible Person: Thelma Bloes Implementation Date: June 30, 2023

Twin Oaks will allocate costs in the accounting system in accordance with the established cost allocation plan. This will be reviewed on an annual basis or as needed.

Finding 2022-001 - Allowable Costs/Activities, Period of Availability and Reporting; Material Weakness Responsible Person: Toneq? McCullough, Director of Transportation Action: During fiscal year 2022, the City?s Department of Transportation recognized a need for additional controls in reviewing and approving contractor invoices prior to submission to the Finance Department for payment. While additional controls were implemented during the year for non-payroll expenditures, developing a similar procedure for payroll invoices was inadvertently overlooked. As of September 2022, the City updated the process by which payroll invoices are approved and paid and the invoices are now approved by the Director of Transportation. The City?s Department of Transportation will begin reviewing and approving the non-financial information in the Annual Operating Statistics Report as of November 2022. Anticipated Completion Date: November 2022

Finding 2022-002 Condition A sample of 40 items were selected for testing. During our testing, we noted one item selected for testing did not contain support of authorization. This was not a statistically valid sample Corrective Action Plan Corrective Action Planned: The Company agrees with the finding and will implement procedures to ensure all invoices approved via email will be stored in our document management and workflow software. Name(s) of Contact Person(s) Responsible for Corrective Action: Daniel Murray, CEO and Timothy McQuaid, CFO Anticipated Completion Date: completed

FINDING 2022-007: ESSER PAYROLL The School Corporation did not have a documented internal control over payroll claims in place relating to the Allowable Activities and Allowable Costs compliance requirements. Corrective Action Plan: Central Office staff will verify and sign reports for FY2023.

Respectfully, the school corporation does not agree with several of the findings in regards to segregation of duties and purchases. First, the SBOA auditors' told the school corporation during the 2019 audit that operating the school lunch program through the extracurricular account was not legal. The school corporation was informed that this account must be transferred to Central Office and a Corrective Action Plan must be in place. This directive was incorrect and pointed out in the official response from November 5, 2019 under IC 20-26-5-4(a)(l l). Second, segregation of duties, oversight, and approval of functions existed in 2019 and are presently occurring daily, weekly, and monthly within the cafeteria program under the corporation accounts and supervision of Central Office. Cafeteria workers record and submit timesheets of duties performed during each payroll period. The Cafeteria Director verifies and signs timesheets to be submitted to the Treasurer and Deputy Treasurer for review and payment from the Cafeteria account. A payroll docket report is sent to the Superintendent prior to payment from the bank. Prior to the 2019 audit, the High School Treasurer spent approximately two hours per day counting cash received each day from school lunches purchased. She also receipted those funds it into the software system, made deposits to the bank, paid invoices for food expenses, and processed part of payroll. Tasks conducted by the High School Treasurer were segregated by a timesheet and supervised by the High School Principal. All those tasks were shifted to Central Office in 2020 and are now segregated to the Treasurer and Deputy Treasurer. The Treasurer documents hours spent on Cafeteria accounts on a timesheet for review and signature by the Superintendent. Financial reports of expenditures and revenues are provided for review and oversight to the Superintendent and School Board at monthly board meetings. Third, RSSC has a small Central Office consisting of a Superintendent, Treasurer, Deputy Treasurer, and Secretary. It has no Assistant Superintendents, Human Resources Director, or Business Manager. Each person in Central Office wears multiple hats and performs multiple duties each day. It was noted in the Audit Report filed from July 1, 2008 to June 30, 2010 that " ...Randolph Southern School Corporation is unable, due to financial limitations, to employ additional personnel to segregate duties in our receipts and cash and investment balances. This statement would apply to all of our internal controls. " The circumstances for RSSC have not changed in the audit periods from July 1, 2010 through June 30, 2022. Corrective Action Plan: The School Board had chosen not to add additional staffing due to costs. RSSC is still unable to segregate duties for financial transactions and reporting. Fourth, the Cafeteria Program only has one full-time staff member, the Cafeteria Director. Eight part-time cafeteria workers prepare and feed up to 300 students each day. This food service program is one of the best run programs in the State oflndiana. It has not had one food preparation or sanitation violation from IDOE or Department of Health in the last 12 years. Fifth, the Cafeteria Program is economically efficient and fiscally responsible. The account carries at least a 3-month cash balance at all times. This success is a direct result of oversight by the combination of the Superintendent, Treasurer, and Cafeteria Director. RSSC adopted board policy 6114 Cost Principles-Spending Federal Funds on May 9, 2016. RSSC has had an Indirect Cost Rate in place since 2013. The adopted policy allows the school corporation to apply Indirect Costs to all federal funds including the Cafeteria account. On December 5, 2019, email communications between the Dr. Donnie Bowsman, Superintendent and Tina Herzog, IDOE Assistant Director of Operations and Food Distributions clearly state the school corporation can apply the Indirect Cost Rate to the Cafeteria account. The email communication clearly states that the high cash balance was a result of not applying the Indirect Cost Rate to the Cafeteria account (See Exhibit 1 Emails). The Indirect Rate was approved by the IDOE Office of School Finance and existed prior to the audit years being referenced in the finding. Technically, the prospective portion (going forward for the next school year) as referenced on pages 24-25 of USDA Indirect Cost Guidance Manual pertains to the 2013 Fiscal Year. Moreover, the fact was reiterated by the IDOE School Nutrition Office with email communications on December 5, 2019, not 2021 or 2022 as referenced in the finding. RSSC has not charged or recouped the Cafeteria Account the Indirect Cost rate for many years and has subsidized this account which should be independent and self-sufficient. The School Corporation did not apply the Indirect Cost Rate in 2020 or 2021 because we were not sure how many students would be eating and how fiscally sound the account would be due to students not attending school because of COVID. Corrective Action Plan: The Indirect Cost Rate will be applied and collected in the future prior to June 30 of each current fiscal year. It should also be noted that in 2021, RSSC purchased a new cafeteria dishwasher utilizing ESSER II funds. This unit was 20+ years old and needed to be replaced in order to continue feeding children and to run the food service program. This expense could have been and should have been a direct cost of $58,189 to the Cafeteria account. However, due to the unknown circumstances of COVID, the RSSC could not take a chance. The ESSER II grant is still open and we are now questioning whether this expense could be charged directly to the Cafeteria account. Those ESSER II fund could be utilized for staffing to support student learning loss and remediation. Sixth, COVID caused this financial account to increase exponentially from 2020 to 2021. ESSER funds were provided by the federal government to provide free lunches to every child which paid the food operations expenses for two school years. Student participation of eating school lunches increased during these time periods. Additionally, staff members were receiving hazard pay incentives on top of their regular hourly rate. Further, the School Corporation and Cafeteria Program took on the enormous task of feeding children over the summers of 2020 and 2021 when COVID cases were at its peak. The cafeteria personnel fed 5286 and 5740 students respectfully during those summers. The number of meals served during the summer almost equaled the total amount of meals served during the entire school year for each respective academic year. These additional meals created additional unexpected revenues for the fiscal year. The school corporation did not charge mileage for satellite lunches being delivered or indirect costs.

See corrective action plan for chart/table.

Finding # 2022-005 Significant deficiency/immaterial noncompliance over federal awards U.S. Department of the Treasury 21.019 Coronavirus Relief Fund 21.027 Coronavirus State and Local Relief Funds Finding: Amounts charged to the contract were unallowable. Recommendation: Procedures should be implemented to provide oversight of contract billings and accounting records to ensure activity is charged and recorded according to contract requirements. Corrective Action: We will provide additional training to staff on proper expense charges as well as review invoices to ensure all expenses are allowable before requesting reimbursement. Anticipated Completion Date December 31, 2023

PENN MANOR APARTMENTS 601 S Penn Ave. Independence, KS 67301. Corrective Action Plan August 17, 2023 Penn Manor Apartments HUD Project No. 102-11030 Audit performed by Pettit & Company, LLC 3725 E. Southport Rd., Suite A Indianapolis, IN 46227 Period covered by the audit Year ended December 31, 2022 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2022-001 Allowable Costs Statement of condition: The Organization repaid $7,200 on a related party loan without surplus cash or HUD approval. Comments on the Finding and Each Recommendation: This was a finding from prior year, and once it was brought to our attention, all payments ceased. As reported in our prior year finding, the owner's SEK Lutheran's, Inc, a non-profit organization, had no cash flow and ne?_ded the funds loaned to Penn Mam to be repaid as soon as possible. Corrective Action Planned or Taken: The action taken was to immediately cease the payments, and wait until there are residual funds available to repay the loan or HUD approval is granted. Finding 2022-002 Cash Management Statement of condition: The Project is not current on its mortgage at December 31, 2022. Comments on the Finding and Each Recommendation: The mortgage was not current in December. The managing Agent had taken a temporary leave due to a personal family issue. The agent believed the mortgage and other bill were being addressed, however, due to high vacancies and the strains from covid, there was a strain on the project's cash flow. Corrective Action Planned or Taken: We have caught up on the mortgage and continuing to stay current. We contacted our HUD Representative and have worked out a financial plan to get matters resolved and back on track. We are filing monthly reports with HUD and have also seen a decrease in our vacancies which is further helping with the finances.

During the COVID-19 pandemic, DCH Health System (DCH) developed a methodology to identify eligible costs in accordance with the Health and Human Services (HHS) produced COVID-19 Provider Relief Fund (PRF) Reporting Requirements and FAQ guidance. DCH's methodology identified costs used to prevent, prepare for, and respond to coronavirus that fell into the following categories: COVID-19 specific costs, direct and indirect incremental costs due to COVID-19, and calculated lost revenue. To calculate direct and indirect incremental costs due to COVlD-19 for DCH Regional Medical Center, DCH leveraged HHS FAQ guidance from October 28, 2020, that introduced examples demonstrating how providers could calculate marginally increased expenses related to coronavirus using a reasonable methodology comparing pre-pandemic to post-pandemic average expenses for an office visit. OCH utilized this methodology to calculate direct and indirect incremental costs due to COVID-19 on a per-patient discharge basis, which is akin to an office visit for a hospital, per the HHS FAQ guidance. Though this specific example was removed in subsequent versions of the FAQ, HHS never communicated that the guidance that DCH relied upon to calculate incremental expenses was incorrect. DCH's view is that the total cost of patient discharge includes direct patient care and indirect costs (overhead and general administrative (G&A) costs). Indirect costs (e.g., facilities, maintenance, utilities, and management salaries) were incurred by DCH to prepare, prevent, and respond to COVID-19, consistent with the intention of the purpose of the PRF to 'provide financial support to providers who experienced lost revenues and increased expenses during the pandemic in order to maintain national health system capacity.' For instance, the ability to serve COVID-19 patients relied on incurring utility expenses to keep ventilators and other equipment functioning, of which the organization utilized well more than the norm which resulted in higher utility costs. These costs were vital for accommodating COVID-19 patients during the pandemic, just as they were necessary for serving other patient types before the onset of COVID-19. These incremental indirect costs were also not reimbursed through other sources. DCH allocated indirect costs in accordance with other accepted government rules as defined in various government regulations such as 2 CFR and the Federal Acquisition Regulation. The indirect costs allocated to patient care costs were considered part of the total cost of patient discharge. In addition, though DCH calculated lost revenue, DCH did not report on lost revenue as part of the system's use of funds (please note that there was one reporting period where Fayette had to report separate from DCH because of targeted funds received. Fayette did report lost revenue in that period based on a budget to actual calculation). DCH believes that the funds identified and reported are consistent with HHS guidance and the spirit of the law to maintain national health system capacity It is DCH's understanding that Single Audit Finding 2022-001 is particularly focused on DCH's approach to identifying indirect incremental costs due to COVID-19, citing these expenses as ineligible costs that were included in the HHS PRF portal submission. Similarly, DCH did not report lost revenues, resulting in 'inaccurate lost revenues reported.' Both FORVIS and DCH acknowledge that DCH incurred eligible expenses and lost revenue sufficient to cover the PRF funds received. Therefore, based on the FORVIS finding, and assuming the finding is sustained, DCH will implement processes to submit future PRF reports as suggested in Single Audit Finding 2022- 001, which includes identifying specific individual expenses incurred during the reporting period to prevent, prepare for, and respond to COVID-19, rather than utilizing the initial HHS guidance for calculating incremental costs due to COVID-19. In addition, OCH will include lost revenue in the PRF portal submission.

Action taken in response to finding: The required FFATA reporting was completed and will be monitored by management going forward. Name(s) of the contact person(s) responsible for corrective action: Jeri Ohman.

Finding Number: 2022-003 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles, and Reporting Program: 93.563 Child Support Enforcement 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Lisa DeBoer ? Director of Business Management Jenny Severson ? Fiscal Officer Tiffany Bailey ? Fiscal Officer Michelle Salfer ? County Program Specialist Wendy Crawford ? County Program Specialist Corrective Action Planned: ? Payroll allocations will be reviewed prior to the start of the calendar year and any required updates will be implemented. ? Instructions for completing the report will be reviewed quarterly along with eligible revenues and expenditures. ? Upon completion of each respective report, the County Program Specialist and/or Fiscal Officer will send the report to the other County Program Specialist and/or Fiscal Officer or the Director of Business Management for a secondary review before submission. Anticipated Completion Date: September 30, 2023

2022-003 Deficiencies in controls surrounding payroll expenditures. A. Name of contact person responsible for corrective action: Name: Michelle Cage Title: Chief Financial Officer B. Corrective action planned: The business manager will strengthen controls to ensure supplemental pay and other pay related items are board approved and recorded by the proper scales or rates. Time sheets will be reconciled to each payroll. C. Anticipated completion date: June 30, 2023

2022-002 Weaknesses in controls surrounding non-payroll expenditures. A. Name of contact person responsible for corrective action: Name: Michelle Cage Title: Chief Financial Officer B. Corrective action planned: The business manager will strengthen controls to ensure adequate documentation is provided and approval on purchases. C. Anticipated completion date: June 30, 2023

Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Financial Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021/22 Grant Number: N/A Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Cause: The City?s procedures did not ensure the required written procedures were developed and implemented in accordance with the Uniform Guidance. Recommendation: We recommend the City establish policies and formalize written procedures related to allowable costs in accordance with Subpart E ? Cost Principles. Management Response and Corrective Action: The City of Laguna Beach's Administrative Policies already incorporate Special Procedures for Procurement for Federally Funded Projects and Purchases. These procedures ensure compliance with all relevant Federal requirements when the City expends Federal funds. To further enhance our compliance efforts, management will update the City's Administrative Policies to include additional procedures for determining the allowability of costs in accordance with the conditions of Federal Awards. Name of Responsible Official: Julie Nemes Director of Finance and Technology Services Implementation Date: June 2023

Finding 2022-004: Written Documentation of Uniform Guidance Policies and Procedures - Material Noncompliance Management?s Response: Our commitment to maintaining strong financial controls and compliance with grant reporting requirements remains unwavering. In response to the audit finding and in our ongoing efforts to continually improve our internal controls and procedures, we have taken the following corrective actions to address the identified noncompliance and strengthen our internal controls for compliance: Policy Development: We have initiated the development of comprehensive written policies and procedures that align with the requirements of 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. These policies will outline the necessary steps and guidelines for compliance with grant agreements and cost principles. Policy Review and Approval Process: We have established a formal process for reviewing and approving the written policies and procedures. This process includes involving relevant stakeholders, such as legal counsel, finance, program management, and other key departments, to ensure comprehensive coverage of the requirements and adequate alignment with our operations. Policy Implementation and Training: As the policies and procedures are finalized and approved, we will implement a robust communication and training program to ensure awareness and understanding of the requirements among our staff. This will include training sessions, workshops, and clear dissemination of the written policies throughout the organization. Policy Maintenance and Review: We recognize the importance of regularly maintaining and reviewing our policies and procedures to keep them up to date with any changes in the regulatory environment. We will establish a periodic review process to ensure ongoing compliance and make necessary updates as required. Documentation and Record-Keeping: As part of our enhanced internal controls, we will implement a system for 2 CFR 200, Subpart D?Post Federal Award Requirements, and Subpart E?Cost Principles. This will provide evidence of our adherence to the written policies and procedures. Anticipated Completion Date: Already Implemented Responsible Contact Person: Dr Malik Mamoon Munir, Global Operations Officer, +1 678-580-0853

2022-003: SFSAC Submission Contact Person ? Dorleen Wolbaum, Executive Director Corrective Action Plan ? This finding is noted together with the Board. The Organization will ensure timely submission of the data collection form in the future. Completion Date ? June 30, 2023

2022-006 Internal Controls over Allowable Costs and Cost Principles All Supervisors that oversee federal grants will be asked to attend training to reinforce how purchases should be made following board policy, Louisiana law, and federal grant guidelines. The accounts payable clerk will also instructed not to pay a vendor and/or to return documentation to the appropriate person if missing documents are not included.

Finding 2022-005 - Internal Control over Compliance Federal Awards Position(s) of Agency Personnel taking correction action: Chief Financial Officer Corrective Action: Management has implemented procedures to ensure all internal controls over compliance will be performed in such as way as to ensure documentation of compliance. Date Corrective Action Complete: September 30, 2023