Corrective Action Plans

Management agrees with the finding and will put processes and controls in place to verify timely deposit in the future. The required deposit of $9,507 was made in April 2024 to the residual receipts account.

Comment on Finding: We concur with the auditors' finding that the balance in excess residual receipts was above the limit allowed by HUD and was not remitted per HUD guidelines. Actions Taken or Planned: The Director of Accounting and Property Accountant will review and verify the Residual Receipts balance, determine amount eligible for retainage and return the remainder to HUD in accordance with HUD regulations.

Finding Reference: 2023-001 Description of Finding: Significant Deficiency in Internal Controls over Compliance. Identification of the Federal Program: U.S. Department of the Treasury CFDA 20.019 Criteria or Specific Requirement: Recipients of federal awards must establish internal controls over reports that are prepared and submitted. Finding/Condition: Pursuant to the reporting requirement set forth by the Department of the Treasury, the Organization is required to submit the single audit to the Federal Audit Clearinghouse within 30 days of the issuance of the audit report or nine months after the end of the Organization’s fiscal year. During our reporting period we noted that the audit was not completed and filed timely. Cause: The Organization met the requirements for a single audit for the first time during the year ended December 31, 2023. Due to a lack of expertise in federal grant reporting requirements, the Organization overlooked the requirement to perform a single audit and file with the clearinghouse in a timely manner Corrective Action: In June 2025, Monterey County Business Council employed a CFO Consultant with 30+ years’ experience in finance and accounting who has performed a deep dive into the accounting framework. The Consultant has been engaged to assist the Organization in completing financial and single audits for the years ended December 31, 2022, 2023, and 2024. It is expected that the Organization will be caught up with federal clearinghouse filings by the end of 2025 or early 2026 at the latest. Under the consultant’s guidance, the Organization has made progress in financial reporting and will be filing the 2023 audit by September 30, 2026. Audits for subsequent years will be audited thereafter. Name of Responsible Person: Chris Steinbruner, CPA Questioned Cost: None Chris Steinbruner, CPA MCBC Board Member (831)-222-6111

The organization is in the process of updating its policies to ensure the proper calculation of the MTDC in accordance with program guidelines.

Management agrees with the finding and will implement procedures to ensure reimbursement request documentation and supporting schedules are retained in a centralized location and readily accessible for future monitoring and audit purposes. Anticipated Completion Date: September 30, 2026.

Finding 2023-006: Lack of Management Oversight over Drawdown Requests As the previous employees responsible for these functions did not perform them effectively, the organization now has such in place, whereas a drawdown process has been implemented. As the organization’s drawdowns are typically designated to cover payroll costs, this process now includes the following: • A drawdown allocation schedule for the employee’s making up the amount requested • A budget breakdown by department for the amounts making up the drawdown request • A supporting schedule and related invoices for amounts to be reimbursed (e.g., malpractice insurance, etc.) • A completed Standard Form (SF) 270 that tracks the applicable grant amounts previously drawdown that also specifies the amount to be currently drawn.

Management Response: COR3 has already undertaken proactive measures to strengthen oversight, streamline procedures, and provide tailored guidance to support Subrecipients effectively. Efforts to Promote Compliance and Support Subrecipients. During the past years, COR3 has undertaken significant efforts to assist Subrecipients in meeting regulatory requirements and adhering to COR3 policies and procedures. This has been achieved through tailored guidance provided via individual phone calls and meetings, ensuring that Subrecipients receive direct and actionable support to navigate compliance challenges effectively.Amendments to Chapter 7 (Payments & Cash Management) and SOPs. Recognizing the unique circumstances in Puerto Rico, including challenges related to construction permits and the shortage of construction services, COR3 has proactively amended Chapter 7 (Payments & Cash Management) of its policies and procedures, along with the corresponding Standard Operating Procedures (SOPs). These updates have been thoughtfully designed within COR3’s regulatory authority to account for the realities faced by Subrecipients, addressing delays in project completion and documentation submission. The changes to Chapter 7 include the following enhancements:  Added requirement of the submittal of a 90-day spend plan through the Disaster Recovery System (DRS) to the Request for Capital Advance (RFCA) Pilot Program, notating what the advanced funds will be used for  Eliminated proration selection from the RFCA reconciliation process – Subrecipients will no longer be able to defer the reconciliation of the RFCA.  Revised the term to reconcile the RFCA on or before 180 days from disbursement (RFCA Initial Term), up to a maximum of 12 months from disbursement.  Added requirement to submit monthly RFCA reconciliation RFRs if total reconciliation is not completed within RFCA Initial Term.  Removed requirement to submit a status report within 90 days of RFCA disbursement.  Added Project/RFCA status report requirement within 180 days of RFCA disbursement if total reconciliation is not completed within RFCA Initial Term.  Added percentage range to RFCA Requests in 5% increments up to a maximum of 25%, thereby ensuring that funds being advanced are tailored to the subrecipients’ needs.  Introduced a 25% minimum amount for reconciliation of RFRs to ensure that the advance is reconciled in a consistent manner; certain exceptions apply.  Modified RFR Threshold amounts as recommended but not required.  Implemented yearly notification requirements for interest earned on advances. Additionally, COR3 is amending the Advance Requirement Compliance Protocol (SOP No. 022) to address the non-compliant Subrecipients (1) with a backlog of RFR’s reconciliations, among other related matters. The primary objective of the procedure is to establish clear communication channels and procedures between COR3 and Subrecipients who are not adhering to required policies and procedures. For example, for Subrecipients with RFCAs disbursed 12 months or more which have yet to be reconciled, COR3’s Finance Division will take a series of actions to address noncompliance, starting with a request for documentation such as bank certifications or account statements. Subrecipients will have an additional 30 days to reconcile the RFCA. Failure to do so will result in a recoupment letter demanding the return of unreconciled funds or suspension of disbursements. If noncompliance persists, the Finance Division will issue a final warning letter, detailing the outstanding RFCAs and implementing the suspension of disbursements until the issue is resolved. These comprehensive amendments reflect COR3's commitment to promoting clarity, accountability, and efficiency while supporting Subrecipients in achieving their project goals within the established regulatory framework. Impact of These Efforts COR3’s initiatives have resulted in Subrecipients being better informed about their obligations in managing federal funds, as a result several Subrecipients have voluntarily returned advance payments that were not utilized or reconciled within the required timeframe. These actions illustrate COR3’s strategies in promoting accountability and compliance among Subrecipients and fostering a cooperative environment for financial and operational transparency. This reflects COR3’s ongoing efforts to support Subrecipients in achieving their project goals within the regulatory framework. Corrective Action Plan: Implement and monitor the updates made to Chapter 7 and approve the amendments and implement the new SOP (Advance Requirement Compliance Protocol (SOP No. 022)), to achieve a cooperative environment with our subrecipients for financial and operational transparency. Contact Person: María Cardec, Grants Director Anticipated Completion Date: Completed as of February 28, 2026

Item 2023.006 – Cash Management Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • Prepare written procedures to document the process for Drawdown requests, including the initial review, documented approval process, submission to the funding agency, and the recording of the drawdown in the accounting system immediately after submission • Maintain detailed records of all drawdown requests, supporting documentation, approvals, and correspondence • Conduct regular internal reviews of drawdown activities to ensure compliance with procedures and maintain audit trail • Review drawdown procedures annually to ensure they remain current with funding agency guidelines and best practices

Finding No.: 2023-005 AL Program: 10.555 National School Lunch Program (NSLP) Area: Reporting Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management procedures were promulgated in a SOP on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve coding of grant details and expenditures, increased frequency of reconciliations, and a specific SOP for report preparation. Corrective Action Plan: I. Implementation of a Comprehensive Grant Tracker: PSS will develop and implement a centralized Grant Lifecycle Tracker for all active federal awards. This tool will serve as the primary monitoring mechanism for compliance by recording all financial and programmatic reporting due dates, assigning specific preparers for each report, and establishing automated milestones to ensure sufficient lead time for both the preparation phase and the subsequent supervisory review. II. Deployment of Enhanced Data Analysis Tools: To ensure that quarterly program reporting is both consistent and timely, PSS will develop and implement specialized data analysis tools. these tools will streamline the aggregation of program data, reducing manual entry errors and allowing for more efficient evaluation of program performance against federal benchmarks. Proposed Completion Date: In progress for FY 2024 with completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

The Treasurer has reviewed the corrected SEFA and understands the errors. Funds will be reported accurately in the future.

Criteria: Regulations require that the Organization must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient, to comply with 2 CFR § 200.305(b). Condition: The 93.493 grant is a reimbursement type grant, subject to an approved preliminary expense budget, as the grant agreement does not specifically indicate that it is an advance-type grant. As such, all supported expenses should be recognized before applying for funding or expended within a “reasonable” period subsequent to receipt of funds. Effect: A portion of reimbursement funds were received prior to supporting expenditures being recognized, and funds were not subsequently expended within a “reasonable” period. Questioned Costs: No questioned costs were identified as a result of our procedures. Cause: The Organization applied for grant drawdowns based on projections and expended funds greater than 30 days beyond receipt, resulting in expenditures occurring prior to being identified as qualified expenditures. Recommendation: The Organization should review internal policies related to drawdowns to ensure that drawdowns occur in compliance with Uniform Guidance. Views of Responsible Officials: We agree with finding and will follow prescribed recommendation

Management agrees with the recommendation and will fund the residual receipts account during 2026.

Reporting Recommendation: We recommend that the auditee implement procedures to ensure that Form 19-lA reimbursement requests are reviewed prior to submission to confirm that expenditures are charged to the correct approved budget line items. This may include maintaining a reconciliation between the general ledger, the approved grant budget, and the Form 19-lA, as well as implementing supervisory review and approval of reimbursement submissions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. 2026 Action taken in response to finding: Reoccurring bills such as utilities, loan payments, contract services and credit card payments do not require an expense request to be included for on going bills. We will review our procedures and update our financial policy. 2023 Our financial process includes at least two reviews prior to creating a bill in our accounting system, payments are reviewed by the director or the Deputy Director when signed. We do not use a auto signature all checks are reviewed. 2023 The Grantor billing is a P&L detailed report for that grant and provides reconciliation monthly This is sorted into grant line items designated billable and non-billable for compliance. Total program cost and billable to grant are tracked every month, by the grant finance manager for compliance prior to billing any grants. Timecards are reviewed, expense requests are reviewed and payments are reviewed. Prior to submission of the invoice to grantor. 2023 Grant finance manager pulls copy of timecards, bills and checks to ensure compliance with reimbursements are accurate. Name(s) of the contact person(s) responsible for corrective action: Cora Alyea Planned completion date for corrective action plan: July 2023

Cash Management Recommendation: We recommend that the auditee strengthen controls over grant billing and cash management to ensure that reimbursement requests and advance payments submitted to the pass-through entity are limited to immediate cash needs and supported by allowable costs incurred as of the billing date, in accordance with Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Advance payments for ERAP were temporary during COVID only. At that time the agency was paying out a vast amount of cash each month. This was not a normal time for cash flow or the community. The agency caught an overspend problem, reported to ERAP manager, and returned the funds to ERAP 2.0 by placing a line of credit to support 300K to stabilize cash flow and cover the ongoing problem of late contract renewals which can be 3 to 6 carried by the agency. This is still in place. Name(s) of the contact person(s) responsible for corrective action: Sharon Maggard Planned completion date for corrective action plan: September 2024

Finding No.: 2023-023 AL Program: 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Area: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Questioned Costs: $-0- Contact Person(s): Stacy Atalig, Federal Programs Coordinator, DPW Corrective Action Plan: The Department of Public Works, Technical Services - Highway Branch agrees with the finding. The Highway Branch agrees to be more vigilant in ensuring that all documents are properly reviewed and approved. The disbursement process of program funds, specifically, the process did not include documented review or approval demonstrating that checks and ACH disbursements were verified against supporting documents. DPW, TSD – Highway utilizes the Master PR20 log sheet for each fiscal year to track all Voucher for Work performed under Provisions of the Federal Aid and Federal Highway Acts as Amended (form PR20), Current Bills (drawdowns), and payments made on each. However, payments are either mailed or electronically transferred directly to the vendors by the CNMI Treasury Office. Effective immediately, the Highway Branch will download a copy of all payments made to its vendors directly to each PR20 file. Proposed Completion Date: June 2026

AL Program: 15.875 – Economic, Social, and Political Development of the Territories Area: Cash Management Questioned Costs: $972,335 Contact Person(s): Angelina Phillips, Financial Analyst, Office of Management and Budget (OMB) Corrective Action Plan: Condition 1-2: The Office of Management and Budget (OMB) agrees with this finding. The underlying cause of this issue was the absence of succession planning and cross training, which resulted in a loss of institutional compliance knowledge during a staff transition. When the primary grant administrator unexpectedly left the organization, there was no transition plan, no cross trained backup staff, and no documented standard operating procedure in place. As a result, the departing administrator processed a drawdown request without leaving documentation of the drawdown or the corresponding vendor invoices. The untrained coverage staff, having only been informed that funds were received, subsequently processed the invoices for payment, which led to the timing discrepancy noted in the finding. To correct this issue, we have formally adopted the CNMI Department of Finance’s Internal Control for Federal Grants Management Manual effective May 1, 2025; the Department of Finance’s Federal Grant Drawdown Procedures effective June 20, 2025; and the Department of Finance’s Cash Management Policies and Procedures effective October 1, 2025. Collectively, these policies ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The step by step Standard Operating Procedures we have adopted for internal controls and the drawdown process clearly outline required documentation, approval workflows, and compliance timelines. In addition, we have initiated succession and continuity planning to ensure that at least Finding No.: 2023-016, continued AL Program: 15.875 – Economic, Social, and Political Development of the Territories Area: Cash Management Questioned Costs: $972,335 Contact Person(s): Angelina Phillips, Financial Analyst, Office of Management and Budget (OMB) Corrective Action Plan: one alternate staff member is trained and capable of performing grant administration responsibilities to prevent future disruptions. Proposed Completion Date: Completed

2023-010-Cash Management Suggested Action: Ensure timely payment of subcontracts with minimal delay between time of grant disbursement and expense payment. Responsible Official: Global Finance Director Completion Date: 4/30/2026

Audit Finding Reference: 2023-001 Document Policies and Procedures Over Federal Awards Planned Corrective Action: A Uniform Guidance policy and Procedures document has been adopted. Planned Implementation Date of Corrective Action: The policy was effective 03/21/2025. Person Responsible for Corrective Action: Finance Director

Recommendation: We recommend that the City implement a system of internal controls over the financial close and reporting process that will mitigate the risk of misstatement in accordance with Uniform Guidance, the Wisconsin State Single Audit Guidelines, and the Wisconsin Department of Health Services Audit Guide. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The City is actively working with their auditors to become current with required single audit filings. Name(s) of the contact person(s) responsible for corrective action: Danielle Brown, Director of Finance & Treasurer Planned completion date for corrective action plan: September 30, 2026

2023-011 Timely Grant Draws Material Weakness Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

2023-005 Timely Bank Reconciliations Material Weakness Recommendation: Implement currently adopted policies over bank reconciliations. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

2023-004 Cash Management Material Weakness Recommendation: Auditors recommend filing documentation for grant draws along with payment vouchers throughout the year. Action Taken: Documentation for grant draws and expenditures to support the request for funding is vouchered along with wire transaction documentation that requires the signature of 3 Tribal Council for processing.

Finding No.: 2023-005 AL Program: 10.555 National School Lunch Program (NSLP) Area: Reporting Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management procedures were promulgated in a SOP on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve coding of grant details and expenditures, increased frequency of reconciliations, and a specific SOP for report preparation. Corrective Action Plan: I. Implementation of a Comprehensive Grant Tracker: PSS will develop and implement a centralized Grant Lifecycle Tracker for all active federal awards. This tool will serve as the primary monitoring mechanism for compliance by recording all financial and programmatic reporting due dates, assigning specific preparers for each report, and establishing automated milestones to ensure sufficient lead time for both the preparation phase and the subsequent supervisory review. II. Deployment of Enhanced Data Analysis Tools: To ensure that quarterly program reporting is both consistent and timely, PSS will develop and implement specialized data analysis tools. these tools will streamline the aggregation of program data, reducing manual entry errors and allowing for more efficient evaluation of program performance against federal benchmarks. Proposed Completion Date: In progress for FY 2024 with completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

Developed and implemented a standardized procedures for documenting and retaining support for all grant activity. Reveiwed all grant paperword, reconciled with supportive documentation

Developed and implemented a standardized procedures for documenting and retaining support for all grant activity. Reveiwed all grant paperword, reconciled with supportive documentation