Corrective Action Plans

Finding Number: 2023-005 Assistance Listing, Federal Agency, and Program Name 10.558, U.S. Department of Agriculture, Child Care and Adult Food Program Federal Award Identification Number and Year 15-016-271P-00 Pass through Entity Illinois State Board of Education Finding Type Material weakness Repeat Finding No Criteria Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government," issued by the Comptroller General of the United States, or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Other requirements include: a) Per 7 CFR 226.10(c)(1), prior to submitting its consolidated monthly claim to the State agency, each sponsoring organization must perform edit checks on each facility's meal claim; per 7 CFR sections 226.16(g) and (h), a sponsoring organization must disburse advance and meal reimbursement payments to centers and day care homes under its sponsorship within five working days of receiving them from its state agency. b) Per 7 CFR 226.15(f), each sponsoring organization of day care homes shall determine which of the day care homes under its sponsorship are eligible as tier I day care homes c) Communication from the passthrough entity to return to pre COVID 19 monitoring, as required under 7 CFR 226.16(d)(4)(iii), effective October 1, 2022, where sponsoring organizations are required to perform onsite monitoring of each of its facilities three times every year, which includes requirements to ensure the amount of time between reviews does not exceed six months (unless review average is used). Condition A lack of documented controls as evidence of supervisory review and segregation of duties to ensure compliance with Federal program requirements, specifically over: a) monthly expenditure reports submitted to the passthrough entity b) tier (day care home eligibility) determinations c) subrecipient monitoring Questioned Costs None Identification of How Questioned Costs Were Computed N/A no instances of material noncompliance noted that would result in questioned costs Context a) During testing a sample of 5 monthly expenditure submissions, we noted no formally documented supervisory review in place. Additionally, during testing of 40 disbursements to providers, we noted no formally documented supervisory review to ensure disbursements to providers are made within 5 working days of receipt from the State passthrough entity. b) While gaining an understanding of controls over tier (day care home eligibility) determinations, we noted no controls established to ensure supervisory review of these determinations. c) While testing a sample 40 provider monitoring visits, we noted 3 visits without evidence of supervisory review and 6 visits where the visit was completed and validated in the software by the same individual. Additionally, we noted 16 day care homes and 2 day care centers with less than the required 3 annual on site monitoring visits for the year, and 15 day care homes and 2 day care centers where onsite monitoring performed were more than the required 6 months apart. Cause and Effect A lack of effectively designed, implemented, and operating controls in any of these areas could result in a material noncompliance with program requirements or Uniform Guidance. Recommendation We recommend management formalize documentation of a supervisory review of: a) monthly expenditure submissions before submitting to the passthrough entity, including documented supervisory controls to ensure disbursement timeliness is met within 5 working days as part of this review; b) of data used in making tier/eligibility determinations for accuracy and completeness; and c) of subrecipient monitoring. Additionally, we recommend management work with its passthrough entities to confirm compliance requirements, especially when compliance requirements change as the result of ending or expiring waivers and flexibilities. Planned Corrective Action Plan –Organization will document process that is used for second review of the monthly expenditure submissions by 04/30/2024. There are no instances of the Organization not providing funds to provider within the mandated 5 days, however, the Organization will document the process for provider payments within 5 days by 04/30/2024. The software required to be used by the funder for management of the program does have limitations on how the data input for making tier/eligibility determinations second review is documented. Organization will design process to document this second review has occurred by 04/30/2024. Staffing shortages coming out the COVID-19 waivers resulted in the inability to perform all required Subrecipient monitoring. This staffing shortage was rectified by 08/31/2023. Contact person responsible for corrective action: Loukisha Pennex, Chief of Youth and Family Potential, Anjanette Brown, CFO and Teresa Rodriguez, Senior Director of Grants and Contracts. Anticipated Completion Date: April 2024

FINDING 2023-007 Compliance Requirement(s): Non-Profit School Food Service Accounts Audit Findings: Material Weakness, Other Matters Summary of Finding: There was no documented control in place over the receipt of monthly meal reimbursements. One individual received notification of deposit, received funds into accounting software, and prepared bank reconciliations. There was no documented review of the receipt of monthly meal reimbursements by a second individual not involved in the original receipt process. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The Business Manager and Cafeteria Manager will meet monthly to review the deposit statement from the bank to verify all deposits are accurate and accounted for the Food Service Fund. The bank statement will be initialed by both parties and retained on file in the business office. Anticipated Completion Date: Immediately

FINDING 2023-006 Compliance Requirement(s): Reporting Audit Findings: Material Weakness, Other Matters Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirements: Reporting There was no documented control in place over the review of monthly reimbursement claims. Claims were prepared and submitted by one individual without documentation that they were being reviewed by a second person not involved in the original process. The lack of controls resulted in overstatements in the number of meal counts used for reimbursement purposes when compared to School Corporation supporting documentation. Views of Responsible Officials: We Concur with this finding. Description of Corrective Action Plan: The food service director will enter the claims into CNPWeb Claim reimbursement site using the information from the Point of Sale system reports for reimbursable meals. The Business Manager will then confirm the meal counts before submitting the Claims. The FSMC food service director meets with the Superintendent monthly to review all claims and food service financials. A meeting agenda will be signed by all parties involved and retained on file in the business office. Anticipated Completion Date: Immediately

UWGC has developed a procedure to ensure that prior to submission of invoices to federal awarding agencies, management prepares a monthly analysis based on 211 call logs to support the actual amounts allocated across all programs and invoiced to the awarding agencies that are reconciled to payroll reports, which then will allow UWGC to present evidence that all hours submitted for reimbursement are supported with the appropriate allocation. The process will include management staff from both 211 and finance departments thus maintaining internal controls. Additionally, this procedure will be reviewed at least annually by both departments as it relates to the allocation methodology to ensure that its appropriate given changes in the program and workforce.

UWGC requires the practice of responsible, and reasonable procedures related to minimizing the time betweenreceipt funds from grant funders and disbursement for programmatic expenses as outlined below in the“PROCEDURE: Cash Management” below. The goal of this process is to ensure that federal funds received inadvance of the expenditure are segregated and expended in a manner to minimize the time between date ofreceipt and date of disbursement.

Finding Number: 2023-002 Condition: The College did not follow all the Tier Two arrangement requirements and disclosures. Planned Corrective Action: The College will ensure that regulations related to Tier Two arrangements are reviewed. On a semiannual basis, the College will review all arrangements service providers for compliance with regulations. In addition, the College will review cash management regulations and references such as Dear Colleague letters on the subject matter to remain current with requirements. Contact person responsible for corrective action: Ms. Taranne Roberts and Dr. Sharron T. Burnett Anticipated Completion Date: 06/30/2024

CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action Planned in Response to Finding: Management is aware of the issue and will implement the suggested procedures. Official Responsible for Ensuring CAP: Brent Hinson, Deputy City Administrator/Finance Director, would be responsible for procedures. Planned Completion Date for CAP: Procedures will be implemented in the current fiscal year. Plan to Monitor Completion of CAP: The finance department will review and ensure compliance.

In years prior, the Boys & Girls Clubs of Central Illinois has consistently managed our internal accounting systems and federal grant reporting without incident while working with a 3rd party accounting firm. In 2022 we incorporated an internal fiscal director role to aid in those efforts. The Board of Directors & CEO later discovered a host of performance deficiencies, accounting and reporting errors made during the time period of FY23; causing the negative impact to our FY23 audit which has resulted in two audit findings. Effective October 2023, the Board of Directors along with the CEO took immediate action by making the following changes to ensure no future issues will negatively impact our internal accounting and reporting systems. 1 - The Fiscal Director role was permanently eliminated upon further investigation. 2- BGCCIL hired a 3rd pary accredited CPA firm who now performs all fiscal duties including general ledger classifications, producing monthly financial reports, and other important accounting functions.

2023-002 – Foster Grandparent Reporting Statement of Condition – The Organization double counted expenditures for the Foster Grandparent program in their tracking spreadsheet in the prior year. Since this is a three year grant period, the Organization intended on correcting this error in the current year draw downs but was not. Cause of Condition – The Organization double counted expenditures for the Foster Grandparent program in their tracking spreadsheet. Recommendation – The Organization should consider the costs and benefits of establishing a financial management system that provides for the identification, in its account, of all funds expended related to federal funding to ensure that expenditures are not double counted when reported for reimbursement. View of Responsible Officials and Planned Corrective Action: The Organization will review procedures and processes around reporting of expenditures for grants, specifically the Foster Grandparent reporting. In-depth training will be provided to Finance and applicable staff in relation to multi-year grants. Anticipated Date of Completion: Ongoing analysis

2023-001 – Nutrition and Transportation Reporting Statement of Condition – The Organization filed billing reports for nutrition and transportation services to AgeSmart Community Resources that did not agree to the nutrition and transportation detail records. Cause of Condition – The Organization’s staff erroneously made mathematical errors and incorrectly billed all 5-meal deliveries as 7-meal deliveries. Recommendation – The Organization should consider the costs and benefits of hiring additional expertise or training existing staff, as well as, implementing a monitoring process to ensure the Organization’s billings are accurate and in accordance with the procedures prescribed by the funding agency. View of Responsible Officials and Planned Corrective Action: The Organization will review procedures and processes around reporting of units; implementing a double check system between the clerk and supervisor to reduce the risk of human error in logging units. Review of practices regarding adjustments to units will be completed and procedures will be updated. Quarterly audits will be implemented to ensure accuracy. Anticipated Date of Completion: Ongoing analysis

Unpaid Expenses on Draw Request (2023-004) Federal Agency: Environmental Protection Agency Federal Program Title: Capitalization Grant for Clean Water State Revolving Fund ALN Number: 66.458 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that management ensures invoices are approved by the City Council before submitting the draw request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will monitor all draw requests and ensure that expenses are approved by the City Council before reimbursement is requested.

Auditee’s Response and Planned Corrective Action Since February 2022 the Fee Accountant has paid the bills monthly and made sure to reimburse the Revolving Fund accordingly if funds are available. Unfortunately, the State Program has not had a rate increase with all the changes going on. Their cash flow is very low and a rate increase is being implemented for the FY24 Budget. There is another rate increase taking effect for FY25. This should allow the State program to reimburse the Revolving Fund fully. As of March 2024 the State owes less than $25,000 to the Revolving Fund. Planned Implementation Date of Corrective Action: July 2023 Person Responsible for Corrective Action: Windsor Locks Management Team working with the Fee Accountant monthly.

Condition: The District has not adequately established internal controls to ensure that net cash resources are being properly monitored. Plan: Internal controls will be established and implemented related to the cash management compliance requirement, including monitoring accumulated cash balances and ensuring that balance does not exceed 3 months of the average progam expenditures. Anticipated Date of Completion: 6/30/2024 Name of Contact Person: Mike Weaver, Superintendent Management Response: There is no disagreement with this finding and internal controls will be developed to monitor the net cash resources of the nonprofit school food service.

The District will work with their contractors to ensure the prevailing wage clause is included in the contract and certified payrolls will be received in the future.

Criteria: According to 2 CFR, Part 200.303 of the Office of Management and Budget’s Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal controls to ensure compliance with federal statues, regulations, and the terms and conditions of federal awards. Condition: Domestic Abuse Intervention Services, Inc.'s internal controls over review of cost allocation journal entries, allowable costs and activities, period of performance, cash management, matching, and reporting were not properly documented. Cause: Sufficient training was not provided to individuals responsible for the documentation of internal controls over compliance requirements. Effect or Potential Effect: This could result in noncompliance, disallowed costs, or discontinuance of federal funding. Recommendation: We recommend formally documenting the controls over each area by providing additional training on documentation and forms to provide evidence of review. Views of Responsible Officials and Planned Corrective Actions: Domestic Abuse Intervention Services, Inc. agrees with the finding. DAIS will implement effective and written procedures and training for the review of cost allocation journal entries, allowable costs and activities, period of performance, cash management, matching, and reporting. The written procedures will explicitly lay out the processes for review and approval of each of these compliance components per each federal Assistance Listing that DAIS receives. The Director of Administration will use the most up to date 2 CFR Part 200, Appendix XI - Compliance Supplement to identify the specific compliance requirements for each of the Assistance Listings and create the written procedures. All reviews and approvals will also be documented henceforth. Shawn Walker, Director of Administration, will oversee the implementation of this corrective action.

Condition: The tenant security deposit cash account was insufficient to cover the tenant security deposit liability. Response: The Project is experiencing escalation of operating costs and management is going to request a Budget Based Rent increase for the property. Management believes that it will then be able to fund the shortfall in the security deposit cash account.

Plan: The District will have a dual review process so this mistake does not happen again.

Plan: The District receives notices from our Medicaid consultants reminding us multiple times before the deadline comes. If the district has not submitted by the second notice, we will schedule a meeting to dedicate time to submitting on time.

Plan: The District will keep physical copies of reports and claims submitted. As students switched categories (free, reduced, and paid), the electronic system failed to keep that in account, leading to discrepancies.

The YWCA will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.

The YWCA will implement the following changes in its accounting procedures. Each month, an aged open accounts payable report will be produced as part of the month end closing. Invoices that are past due will be paid in the following batch of payments (which are typically run weekly). If it is determined that the invoice is not being paid for a valid reason, it will be removed from accounts payable at that time.

The YWCA will implement the following changes in its accounting procedures: 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.

Finding 2023-003 REPORTING ALLOWABLE/ALLOCABLE COSTS We have made progress in allocating allowable costs to specific contracts in our accounting system. Last year we implemented a detailed customer/job tracking capacity in QuickBooks and have created a coding system to match all income, payroll costs and most other types of spending to specific customer/jobs. As the audit indicated, however, we continue to face challenges in properly assigning some shared costs (such as fringe benefits and utilities in shared facilities) to specific contracts in our accounting system. Costs were incurred and supported the operation of the contracts reviewed but we recognize that we need further improvement in how we allocate these costs to individual contracts in our accounting records. We will modify our financial procedures to document our allocation approach for fringe benefits and shared cost. We will also and put new controls in place to monitor cost allocation by contract (where required) on a quarterly basis. All improvements in accounting by customer/job will be implemented for the full fiscal year ended June 30, 2024. Finding 2023-

The District has for many years adhered to the Uniform Guidance procurement codes as established under Section 200.320. The East Casey County Water District shall follow all State and Federal Guidelines as they relate to procurement.

Management made the deposit.