Corrective Action Plans

Name of Contact Person Responsible for Corrective Action Plan: Jerry Deloach, Chief Risk Officer - Enterprise Risk Management Corrective Action Plan: The City of Atlanta?s Office of Enterprise Risk Management (ERM) will calendar the deadlines for filing of reports 90 days from the filing date and each 30-day period thereafter until the filing date and filing of the report. In addition, the Office of ERM will calendar the filing date two weeks prior to filing date. ERM will file the report two weeks prior to the filing deadline date and provide the City of Atlanta?s Grants Accounting team with a copy of the filing. Anticipated Completion Date: June 30, 2023

IN REGARDS TO COVID-19 EDUCATION STABILIZATION FUND - ASSISTANCE LISTING NO. 84.425C, 84.425D, 84.425U, 84.425W; GRANT PERIOD -- YEAR ENDED JUNE 30, 2022 THE DISTRICT WILL IMMEDIATELY PUT MEASURES IN PLACE TO ENSURE THAT ALLOWABLE COSTS ARE CHARGED TO THE GRANT. THIS WILL BE COMPLETED TODAY NOVEMBER 14, 2022.

Finding no.: 2022-007 Contact person(s) responsible: Sally Alworth, Controller Corrective action planned: MPD made a software transition to ADP Workforce Now in September 2022. With this new system in place, all new hires, pay rate adjustments, bonuses, benefits withdrawals, and terminations are initiated by the Human Resources department and approved by the Director of Human Resources. These changes are transferred to the payroll side of the software, where the Payroll Specialist can incorporate them into the next payroll. These fields cannot be adjusted by the Payroll Specialist; changes must be initiated by Human Resources. After timesheets are entered and approved for the bi-weekly pay cycle, the Payroll Specialist generates a draft payroll register and sends the register and a list of all payroll changes for the period to the Controller for review. The Controller confirms that any pay rate changes are processing correctly, reviews any bonus payments, checks entries for new hires and terminated employees, and reviews the pay detail for a regular sample of employees, comparing those entries to the prior pay cycle. If corrections are required, they are made, and a new draft register is generated. Payroll is submitted following the Controller?s approval, and a register of the transmitted payroll file is added to the electronic Payroll folder on the network. The Controller also reviews this file to ensure that no changes were made between the initial approval and final transmission. Anticipated completion date: August 1, 2023

Finding no.: 2022-002 Contact person(s) responsible: Sally Alworth, Controller Corrective action planned: As of April 1, 2023, MPD has adopted a new written policy for administrative cost allocation. Costs that are not allowable for federal grants are flagged both on timecards and on purchasing transactions with a subaccount code that segregates them from overhead allocations. Costs related to facilities ? rent, equipment leases, office insurance, shared supplies, depreciation, etc. ? are now allocated to departments based on the square footage occupancy of each department, calculated using the guidance referenced in 2 CFR 200. Administrative costs that serve the entire organization such as Human Resources, Accounting, outsourced IT support, etc., are allocated to each department based on headcount, as we consider the number of personnel per department to be the best estimate of supporting services required by each team. The Payroll Specialist generates a current employee roster by department at the end of each month, which is used to update the administrative allocation. Once all costs have been allocated to the department level, both facilities and administrative costs are allocated down to individual grants based on the proportion of total wage costs assigned to each grant within the department for that month. Anticipated completion date: May 15, 2023

Finding no.: 2022-001 Contact person(s) responsible: Sally Alworth, Controller Corrective action planned: In December 2022, MPD hired an experienced Payroll Specialist, and in April 2023, the agency brought on a new Controller. As of April 15, 2023, all staff report hours through ADP Workforce Now timecards for each pay period. Codes for active grants, as well as MPD?s unrestricted general fund, are programmed into a custom field in ADP. Staff who work across multiple projects select a grant code for each timecard entry. Timecards are approved by the employee and then reviewed and approved by a supervisor prior to payroll processing. Based on timecard entries, the ADP software produces a general journal entry allocating wage and payroll tax cost to each grant and to the agency?s unrestricted general fund, and this entry is added to MPD?s accounting system after each pay cycle. Anticipated completion date: May 15, 2023

Finding 2022-003: Time and Effort Reports The Light House finance office is working with Paylocity account representatives to identify how to track the Time and Effort results in our payroll system. Until that is accomplished, The Light House Finance team is tracking the time and effort through a Microsoft Access database and creating Time and Effort reports on a Quarterly basis. All Time and Effort reports will be signed by the employee, the Director of Finance and the Executive Director. Responsible Party: Terry W. Brukiewa, Expected completion date: 6/30/2023

Management?s Response to Known Questions Cost Non-Major Federal Programs with Known Questioned Costs in Excess of $25,000 2022-001--Allowable Costs/Cost Principles Federal Agency: U.S. Department of Health and Human Services Federal Program: ALN 93.575 - Child Care and Development Block Grant - Passed through New York State Office of Children and Family Services. Grant/Pass through Number: A-11279 Grant Period: Year ended April 30, 2022 Condition: The Organization expended Child Care Stabilization Grant funds on the resurfacing of a parking lot. Criteria: In accordance with Child Care and Development Block Grant regulations (45 CFR 95.56(b)(1)) no funds shall be expended for the purchase or improvement of land, or for the purchase, construction, or permanent improvement of any building or facility. 45 CFR 98.2 defines ?facility? to include real property used for a childcare program. Cause: The Organization relied on preliminary information provided by the grantor in its decision to use the grant funds to increase accessibility to the childcare center by resurfacing the parking lot. The federal program was not initially identified by the grantor or verified by the Organization prior to the Organization expending the funds. Context: The condition was identified through other audit procedures undertaken during the audit of the financial statements and was not identified as part of a statistically valid sample. The condition was not identified in other audit testing and appears to be an isolated incident. Effect: The Organization was not in compliance with federal allowable cost principles and the related costs may need to be returned. Questioned Costs: $66,830 Recommendation: Procedures should be put in place to ensure that the Organization has confirmed the source of grants funds, as well as any limitation on allowable costs, prior to expending the funds. Managements Response: At the time of our decision, we be believed this cost to be allowable. This based on a webinar by New York State Head Start Collaboration office on the Stabilization Grant on 9/13/2021. During this webinar the question was asked about a parking lot, and it was indicated that we need to get 3 quotes and ensure prevailing wages are paid. At the time the frequently asked question from the state dated 7/20/2021 did not directly address resurfacing a parking lot. This was done to fill several potholes for children and building safety. The parking lot was done in November of 2021. On 4/19/22 the New York States frequently asked question were updated to specifically noting that resurfacing a parking lot was not an allowable use of funds. While we believe our decision was based on information that indicated the cost was allowable at the time of the decision we have since updated our policies and procedures to strengthen them. The Executive Director Janett Rodriguez (jrodriguez@hseoc.org) and Finance Director Sam Breyer(sbreyer@hseoc.org) are responsible for get board approval during the November 1, 2022 meeting and implementation of the below adjustment to our policies and procedure. 1. HSEOC has updated our policy FIS-30-0106 Procurement procedures to include a. HSEOC will get in writing where practical for funding not under covered under 45 CFR part 75. b. HSEOC will also get conformation from the nontraditional funding sources. 2. HSEOC training plan has been updated to include training for additional nontraditional funding sources for the Executive Director, Finance Director, and any Service Area Manager that may manage the funds when these funds are awarded. 3. Filling out of a purchase order process has been updated to include funding source that are not traditional to allow to allowability as a check point. Executive Director, Janett Rodriguez (jrodriguez@hseoc.org) 845-422-8379, and Finance Director, Sam Breyer (sbreyer@hseoc.org) 845-613-3089 are responsible for the implementation of the corrective action plan. Sincerely, Samuel A. Breyer Finance Director

Fiscal Agent and financial assistant recently met with a contact with the ODJFS fiscal team to help create a spreadsheet to monitor youth spending. Moving forward, the Fiscal Agent will be tracking quarterly and reaching out to subareas on progress.

Responsible Party: Felicia Milton, CFO Anticipated Completion Date: March 30, 2023 ELC Management will make sure that measures are in place to monitor and ensure that the Coalition will remain in compliance with grantor administrative expense requirements.

Reporting views of responsible officials and planned corrective actions Management will put in place controls and procedures to annually evaluate the percentage of time staff dedicate to the organization to determine the correct allocation for payroll.

Reporting views of responsible officials and planned corrective actions Management will ensure that moving forward there are controls in place to ensure expenses are captured in the correct fiscal period and that at year end there is a final review of the transactions to ensure that everything is not only properly entered, but properly classified as well.

Finding No. 2022-002 Program: U.S. DEPARTMENT OF EDUCATION Passed through the Commonwealth of Massachusetts?Department of Elementary and Secondary Education Material Weakness 2022-002: Special Education Cluster ? SPED Grants to States, IDEA, Part B (Assistance Listing #84.027) Pass-through program number: 0240-577419-2022-0645; Fiscal year ending June 30, 2022 Auditor?s Recommendation: The District should review currently established policies and procedures for maintenance of time and effort certifications as established within adopted grants manual. Personnel should review established policies and procedures on a routine basis to ensure the District?s compliance with all aspects of the District?s established policies and procedures as well as individual requirements pursuant to OMB. Established policies and procedures should be reviewed on an annual basis to ensure continued compliance with ever changing federal compliance and other financial reporting requirements. Action Taken: As indicated by the auditor, the budgeting for the 240 SPED allocation grant in fiscal year 2023 has been changed to exclude personnel costs (salaries & wages) subject to the ?time & effort? certifications. Therefore, ?time & effort? requirements will no longer be associated with this program. District personnel will continue to review established grants policies and procedures manual with current federal awards administration.

2022-003 Procurement Policy We will adopt a revised procurement policy that includes procedures to comply with the requirements outlined by Part 200.320 of the Uniform Guidance. We completed the adoption 0f the compliant policy in February 2023.

For future disasters, the City will discuss with all vendors exactly what documentation will be required before work begins.

This lapse was a result of delay in submission and approval of time charged by a consultant (operated outside of our automated time sheet controls). We will ensure the allocation is done after the actual time charge is made. We will monitor more closely and train the finance staff in our subsidiary for charging depreciation to the projects.

The District will ensure that all employees not on a formal allocation plan or entirely allocated to a single source complete daily activity reports.

Finding Summary: 36 out of 60 expenditures tested lacked timely approval of employees? actual time spent on the program. 5 out of 60 expenditures tested lacked employee signatures for certification of actual time spent on the program. 6 out of 60 expenditures tested were based on estimated fringe benefits. When compared to actual fringe benefits incurred, the amounts allocated to the program exceeded actual costs incurred Responsible Individuals: Program Directors, Director of Management Reporting Corrective Action Plan: Procedures will be established to ensure employee time charged to federal grants is documented, signed by employees, and reviewed and signed by program directors before each drawdown. Only actual fringe benefits will be charged to federal grants. Anticipated Completion Date: June 30, 2023

All employees paid by Cost Allocation will be charged to the programs based on time sheets, this was fully implemented June 15, 2022

March 2, 2023 Shenandoah Area Agency on Aging respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, Virginia 22801 Audit period: September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT 2022-004: Authorized Signer for Bank Accounts Condition: Four bank confirmations signed by the executive director were sent to financial institutions holding SAAA assets as part of our audit were denied due to being signed by an unauthorized individual. Criteria: As part of management's responsibility to safeguard assets, the authorized signer for bank accounts should be documented. Cause: Management was unaware the listing of authorized check signers had not been updated by the bank as requested. Effect: It is critical for an entity to be able to access its cash deposits held by financial institutions. When a listing of authorized signers is not updated, the entity opens itself to opportunities for loss. Terminated employees may still have access to organizational assets or the organization may be prohibited from accessing their accounts at financial institutions if there is no perceived authority to access the funds. FINDINGS-FINANCIAL STATEMENT AUDIT (Continued) 2022-004: Authorized Signer for Bank Accounts (Continued) Recommendation: Management or governance should determine who has access to bank accounts and ensure only the appropriate parties maintain ongoing access for the safekeeping of the organization's assets. Planned Corrective Action: This finding was caused by the bank not updating its signature cards as requested by the Agency. This finding was immediately corrected once identified by the auditors. 2022-005: Material Audit Adjustments Condition: During the audit, we detected one material misstatement in the trial balance presented to us to begin our audit that was considered a material audit correction. Criteria: Generally accepted auditing standards dictates that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Cause: Financial information was missing or inaccurate. Effect: Assets and liabilities were overstated. Recommendation: We recommend that management implement a process to ensure accuracy of balance sheet and statement of activity accounts. Planned Corrective Action: Management agrees with the finding. During the last quarter of the fiscal year, the finance department experienced a vacancy. As a result, we were short-handed. There was one account that was not reconciled in a timely manner. After the year end, the position has since been filled. All significant balance sheets will be reconciled in a timely manner as in previous years. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-001: Cost Sharing Fees, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition services and Special Programs for the Aging-Title III, Part C2 - Nutrition services, Program income Condition: Individuals receiving Title III-C funded services for home delivered meals were charged cost sharing fees. Criteria: Agencies providing services funded under the Title III-C programs may not charge cost sharing fees for the Title 111-C services under Title III-C per 42 U.S. Code? 3030 c-2(a)(2). Cause: No controls or processes were in place to prevent cost sharing fees being charged to individuals receiving services provided under Title III-C programs. Effect: The cost sharing fees for Title III-C services are not allowed under federal guidelines and therefore these fees are considered a questioned cost. Questioned Cost Amount: $4,400 Perspective Information: Noted two fees were charged for Title 111-C services out of a sample of twenty-five cost sharing fees. Recommendation: Cost sharing fees are not allowed to be charged for Title III-C services provided to individuals. Only voluntary contributions may be made for these services. Management should implement procedures to ensure these fees do not continue to be charged. Planned Corrective Action: Management agrees with the finding. As noted in finding 2022-005, the vacant position, which has now been filled, was responsible for compliance review. Additional procedural reviews and corrected report formatting have been implemented to prohibit cost-sharing fees from being charged to the program. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-002: Unallowable Costs, ALN 93.053 Nutrition Services Incentive Program, Allowable Costs Condition: Administrative expenditures were improperly classified as expenditures funded by the Nutrition Services Incentive Program (NSIP). Criteria: NSIP funds may only be used to purchase domestic foods as outlined under Title 7 U.S. Code of Federal Regulations Part 250.68, Nutrition Services Incentive Program. Grant funding received through NSIP may not be used to pay for administration or other services. Cause: Unallowable costs were improperly classified to the financial records supporting NSIP expenditures and allowable costs were improperly allocated to other projects. Effect: Financial records supporting costs expensed under the NSIP award do not reflect the nature of the expenditures requested for reimbursement. Expenditures were misclassified within the financial records to improper programs and thus are considered a questioned cost. Questioned Cost Amount: $98,327 Perspective Information: Noted in one out of a sample of twenty-five expenditures charged to the Aging Cluster. Two of the items in the sample were expenditures charged to NSIP. We reviewed the list of the remaining expenditures charged to NSIP and confirmed the sample was representative of the entire population. Recommendation: It is critical for the underlying financial records to support an organization's claims for costs reimbursements under federal award programs with adequate documentation. Staff must allocate costs appropriately for allowable costs under each federal program and ensure expenditures charged to the federal programs are for appropriate purposes and are properly classified in the records to avoid noncompliance with federal regulations and program requirements. Planned Corrective Action: Management partially agrees with the finding. We agree that certain amounts were misapplied to the NSIP account. However, the funds did purchase food as required by the grant. We believe this to be a reporting error and not a misuse of grant funds. With the vacant position recently filled, we have added additional review procedures to prevent any reoccurrence of misapplication. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-003: Annual Reporting to VDARS, ALN 93.044 Special Programs for the Aging- Title III, Part B- Grants for Supporting Services and Senior Centers, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition Services, ALN 93.053 Nutrition Services Incentive Program, Reporting Condition: The 13th Aging Monthly Report required by the pass through agency, Virginia Department of Aging and Rehabilitative Services (VDARS) was not submitted timely and contained inaccurate revenue and expenditure data. Criteria: VDARS requires the annual I3th Month Aging Monthly Report to be submitted by November 15t?h The report must contain complete and accurate information as a restating of the monthly reporting for the fiscal year. Cause: The 131 Aging Monthly Report was not reconciled to underlying financial records, resulting in unexplained differences between the report and trial balance provided as part of the audit. Additionally, the report was not submitted by November 15, 2022. Effect: The submission of the 13th AMR was not performed timely and included data that did not agree to underlying financial records. This should have been caught during the course of a review process before submission. Therefore, it is considered a significant deficiency of internal controls over compliance. Recommendation: Ensure reporting is submitted timely by the deadline stated by VDARS. Implement a review process for each monthly submission, including documentation of the review. Reconcile the federal, state and local totals reported in the Aging Monthly Report to the underlying financial records as stated in the financial system to ensure accuracy before submission to VDARS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The AMR report was not filed in a timely manner. As noted in finding 2022-0005, the vacated position during the last quarter of the year was responsible for submittals. We note that the report has since been filed. With the position being filled, we believe the 13th AMR will be filed in a timely and accurate manner as in previous years. If the Federal Audit Clearinghouse has questions regarding this plan, please call Cindy Donaldson, Director of Finance at 540-635-7141. Sincerely yours,

FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS 2022-001: Material weakness in compliance and internal control over compliance: Allowable Costs/Cost Principles: AL 09.610090 Legal Services Corporation Recommendation: We recommend that the Organization assess the current level of staff needed by the Finance Department to ensure grant activity is recorded properly and in compliance with the grant requirements. The allocation of indirect expenses should be reviewed on a regular basis to determine the appropriateness of the allocations throughout the year. As a result of the audit process, management has altered the manner in which indirect costs are allocated, and, if applied properly and consistently, this revised method should resolve the issues associated with indirect cost allocations for 2023. Action Taken: CCLA Management agrees that the timeliness of information is imperative to the preparation and completion of the year-end audit. The staffing levels are being evaluated including the analysis of the appropriate staff categories. Management of the Organization is working on developing a more effective methodology to track grants and the allocation of indirect costs. The new fiscal year budget will include the recruitment of an experienced Contracts & Grant Manager to provide the department with accurate reporting of grant funding. As indicated below, the project to restructure the financial and administrative operations of CCLA is well under way. CCLA?s plan is to complete the implementation of key components of the plan in 2023, in time to completely resolve the issues raised in the 2022 audit and complete the 2023 audit with no material weaknesses or questioned costs. Major Milestones Planned Completion Status Project Start 2/1/23 Done Interim Project Review #1 to CCLA Board 2/15/23 Done Begin Stakeholder Interviews 3/1/23 Done Complete Stakeholder Interviews 4/1/23 Done Interim Project Update #2 to CCLA Board 4/19/23 Done Update Mayuris Pimentel: LSC 4/25/23 Done Completion of Project Assessment Process 5/31/23 Complete First Draft of Plan 6/7/23 Project Presentation to CCLA Board 6/14/23 Written Final Report Delivered to CCLA 6/21/23 Final Report Forwarded to Legal Services Corp. 7/1/23

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls in place to ensure accurate reporting of its Schedule of Expenditures of Federal Awards Name, address, and telephone of District contact person: Leslie Oliver, ESD Business Manager, PO Box 367, Keller WA 99140 (509) 725-1481 Corrective action the auditee plans to take in response to the finding: The District recognizes and acknowledges deficiencies and errors by the District and its financial management contractor in collecting and reporting data pursuant to its Impact Aid application to the Federal Department of Education. While it has not been possible to identify how these originated, they appear to have been in place for a number of years, perhaps more than a decade, related to Washington State?s broad school choice policies and, not identified in previous audits by either Federal or State agencies. Regardless, the District has satisfactorily resolved outstanding data collection and reporting issues with the Department and has put in place administrative controls via training and oversight to comply with requirements. In the past ten months since the deficiencies were identified, the District has taken the following steps to address those and to come into compliance. The District Superintendent, District Secretary and Chair of the School Board were tasked with communicating and negotiating with Department officials. In a series of Zoom meetings, trainings and phone calls, the District team was made aware of the deficiencies, provided with guidance of strategies to correct those and with guidance on addressing the effects of Washington State?s school choice policies on Impact Aid. As a result of that guidance, the District corrected its data collection and validation methodology, proposed and negotiated tuition agreements with three adjoining Districts, proposed and negotiated repayment agreements with those Districts and the Department. Future data collection and validation will be reviewed by the District?s financial management contractor, Education Service District 101. District administration and Board will send representatives to attend the annual conference of the National Association of Federally Impacted Schools in Washington, DC, and to meet with Department staff to review the application and its data. The District will take part in any relevant training opportunities offered by the Department or by the Office of the Superintendent of Public Instruction. Anticipated date to complete the corrective action: immediate action in 2023

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: The error identified above was made on a student?s record who did not officially withdraw from the University. As required by federal regulation, an ?all F?s? report is pulled at the end of each term and a determination is made for all students included on the report whether or not they attended classes until the end of the term. The student identified by the auditors was determined to have not attended the full Fall term. A return of title IV calculation was promptly processed by the Associate Director on the Department of Education?s website. The R2T4 calculation could not be processed via the SIS since the student did not have an official withdrawal date entered. The student loans were returned timely, however, the parent PLUS loan was missed in returning the funds. Subsequently the student contacted our office to challenge the withdrawal date and claimed he had attended classes all term and earned all of the loan funds that were disbursed for the term. There was no documentation in our SIS so the loans were reinstated in error. Corrective Action Plan: R2T4 procedures were updated to include a secondary confirmation of the return of loan funds according to the calculation. This secondary review will be scheduled at the time the R2T4 calculation is processed. Further, the procedure was updated to include entry of notes on the student?s electronic record to avoid reversal if challenged by the student. Responsible Person: Chilwana Thompson, Associate Director Implementation Date: August 1, 2022

2022 ? 001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619 - 2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): Unknown Award Period: July 1, 2021 through June 30, 2022 ? Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the District implement procedures and controls in relation to the required Coronavirus State and Local Fiscal Recovery Funds, to ensure they are completed accurately and timely going forward. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: The District will implement procedures and controls over federal funds to ensure all requirements have been met. Name of the Contact Person Responsible for Corrective Action Plan: Amanda Heilman, Director of Finance and Operations Planned Completion Date for Corrective Action Plan: June 30, 2023

2022-001 - U.S. Department of Health and Human Services - Nebraska Department of Labor ? Temporary Assistance for Needy Families ? 93.558 Criteria or Specific Requirement ? Management is responsible for implementing and effectively operating internal controls over compliance to mitigate the risk of misuse of the Organization?s federal funds and ensure participating students are eligible based on financial need. The Temporary Assistance for Needy Families (TANF) funds may be used for expenses related to Job?s for America?s Graduates (JAG) Program, which helps low-income students with additional resources in middle and/or high school to help the students graduate. To be eligible for the JAG Program, which is funded by the TANF funds, the students must be low-income, evidenced by qualification for free or reduced lunch. Planned Corrective Actions (Management's Response) - United Way of the Midlands (UWM) has reviewed and updated its policies, procedures and training within the JAG Program to improve retention of eligibility documentation and, in the event such documentation is no longer available, document the validation of eligibility requirements used to support Management?s decision on the applicant?s eligibility. This is fully documented in our Quality Assurance SOP (Standard Operating Procedures). UWM also implemented an additional detective internal control in our JAG Nebraska Invoicing SOP that requires a UWM Finance member independent of the eligibility onboarding process to audit monthly a small sampling of students for proper documentation and eligibility related to TANF invoicing. Management will monitor this regularly throughout the year to ensure procedures are being followed as documented. All changes have been implemented. Anticipated Completion Date - October 15th, 2022

Finding Reference 2022-009 Contact Person: Gerald Moench, Interim CFO (or Emily Buckley, VP of Advancement) Views of Responsible Officials and Planned Corrective Action: In including the questioned indirect cost as a HEERF expense, management only considered the per unit cost threshold, rather than both the per unit cost and the expected life of the items. The audit clarified the regulations and Donnelly promptly notified our program officer, posted a corrected quarterly report and refunded the funds to the Department of Education. Anticipated Completion Date: October 2022