Corrective Action Plans

Finding 2023-053 Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 - Timeliness of Cash Draws Management Views LEO agrees with the finding. Planned Corrective Action LEO has filled a staff vacancy which previously contributed to late draws. Also, LEO will implement additional staff training and management oversight to ensure reimbursement requests are made timely and in accordance with CMIA. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Lora MacKay, LEO

Finding 2023-009 Treasury - Recertification of Clearance Patterns Management Views Treasury agrees with the finding. When the Cash Management Improvement Act (CMIA) program transferred to Treasury FSD in early 2022, there was a lack of well-documented procedures on how to complete program clearance pattern reviews. FSD created a procedure for the review process, but it is not complete. Planned Corrective Action Treasury FSD will continue to gain a better understanding of the clearance pattern review process and thoroughly document the procedures for future fiscal years to ensure compliance with federal regulations. FSD will research how the clearance patterns are determined for each program, identify which programs require clearance pattern review each year, ensure that the SIGMA BI queries are functioning properly for each program under review, and clarify how to interpret the BI query results. Anticipated Completion Date September 2024 Responsible Individual(s) Melanie Alvord, Treasury Lauren Markwart, Treasury

Finding 2023-026 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Grant Reimbursement Approval Procedures Management Views EGLE agrees with the finding. Planned Corrective Action EGLE’s Water Resources Division’s Administration staff reviewed the existing process with staff conducting the administrative review to ensure the technical review will be completed in advance of making any payment. If Administration staff have received a request for payment without the technical review, Administration staff will forward all documents received to the project manager to obtain the technical review. Once the technical review has been completed, Administration staff will conduct the administrative review and process the payment request. Additionally, EGLE subsequently reviewed the reimbursement request noted in the finding to ensure that the cumulative totals requested have been for projects that are consistent with the grant award. Anticipated Completion Date Completed Responsible Individual(s) Phil Argiroff, EGLE Amy Hicks, EGLE

Finding 2023-006 MDE, Security Management and Access Controls Management Views The Michigan Department of Education (MDE) agrees with the finding. Planned Corrective Action For part a., as part of the Michigan Nutrition Data (MiND) 2.0 Implementation Project, MDE will institute a mechanism to capture the person to whom the access has been delegated. MDE will review the policies and procedures with department staff that is responsible for security access controls for the Next Generation Grant, Application and Cash Management System (NexSys) to ensure proper access control policies are followed. For part b., MDE will update policies and procedures to ensure review of all accounts on a semi-annual basis. For parts c. and d., MDE will continue to work with DTMB to find more efficient ways to ensure all non-privileged users are recertified and improve the technical solution to deactivate users after 18 months of inactivity. For part e., as part of the movement of the grants management unit at MDE to a different office, MDE is reviewing the policies around high-risk transactions and will update the policies to meet established standards. Anticipated Completion Date October 1, 2024 Responsible Individual(s) David Judd, MDE

Finding 2023-021 SNAP Cluster, ALN 10.551 and 10.561 - EBT Reconciliations Management Views MDHHS disagrees that a material weakness and material noncompliance exist. MDHHS federal reporting conducts a daily reconciliation of federal draws and authorizations to retailers based on vendor EBT reports. In addition, MDHHS conducts a monthly reconciliation between Bridges, Bridges data warehouse, and vendor EBT reports using daily data to ensure the client information in Bridges and Bridges data warehouse is accurate. The monthly reconciliation process does not impact the federal draw because the daily reconciliation of the vendor EBT report is used for this purpose. MDHHS provided detailed and accurate descriptions of MDHHS daily and monthly EBT reconciliations to the designated federal awarding agency contacts at the United States Department of Agriculture Food and Nutrition Service Agency that are familiar with MDHHS processes and received confirmation that the current reconciliation processes in place are sufficient to comply with federal regulations. Planned Corrective Action MDHHS disagrees with the finding and does not intend to take further action. Anticipated Completion Date Not applicable Responsible Individual(s) Sara Gross, MDHHS

Based on prior year (FY22) findings, the City established the following procedures to ensure payment requests received from subrecipients are paid within 30 days of receipt of a complete request for reimbursement: 1. Department of Human Service Programs (DHSP) Contract Manager reviews invoices within 5 business days of receipt of request for reimbursement from subrecipient. a. If invoice is complete, original date of receipt is recorded. b. If invoice is incomplete, subrecipient is notified of items or documentation that is missing and receipt date is updated to reflect date of receipt of complete invoice. 2. Contract Manager approves payment request and submits to DHSP Fiscal staff for processing. 3. Fiscal staff processes and submits to Auditing Department as Priority payment. Four of the 19 sampled payment requests were received or processed after receipt of the FY22 audit findings, and all of those requests for reimbursement were paid within 30 days of receipt.

2023-003 Finding - Federal Award - Significant Deficiency - Reporting US Department ofCommerceAL#11.611 Context and Cause - The Organization was not made aware by grants, CMTC or prior auditors that the final upload package of the federal reports and requests for reimbursement should have internal control oversight procedures and did not exercise such oversight. Only one individual was responsible for preparing and filing these final documents after such details were reviewed individually throughout the month by other individuals responsible for that review. The payroll time sheet review process was consistently followed, however, and there is not a process for the final processed payroll rep01ts to be reviewed by a second individual.Recommendation: We recommend management implement procedures to ensure the Uniform Grant Guidance and the Compliance Supplement requirements for controls over Reporting, Allowable Costs, and Cash Management are designed and performed. The month­ end checklist currently being used is a good start, and this could be enhanced by adding sections for the above items, and having specific individuals' initial and date on the checklist when the procedures are completed. A fiscal policy and procedure manual would also be a good tool. Action Taken: Manex will update fiscal Policy to include oversight on reporting to funders

In Finding 2023-005, a condition was noted that during the year, the Organization made a draw of federal funds that were not disbursed in a timely manner for program expenditures. Management recognizes the importance of the requirements to disburse federal funds in a timely manner. In response to Finding 2023-005, procedures will be established to minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes by the Organization.

Finding 2023-002 Condition The Organization did not have timely approval of non-payroll expenditures to support preparation of reliable financial reports to grantors. Corrective Action Plan Corrective Action Planned: Improvements have already been made to this process in the current year regarding the timely submission of supporting documentation and authorization and this will continue to be an area of focus in both operations and finance. Name(s) of Contact Person(s) Responsible for Corrective Action: The Director of Accounting, Dawn Bonderczuk, and the Account Payable Clerk or Accountant. Anticipated Completion Date: July 31, 2024.

As noted above, The Trust for Tomorrow continues to add compensating controls each year when possible. For example, a Director of Financial Operations was hired during the last half of the fiscal year under audit and this individual has taken over certain responsibilities, including but not limited to general ledger coding, review and approval of invoices, processing timesheets, and handling expense reimbursement requests. Further, we will continue to review our processes to determine where duties can be segregated amongst existing staff. Additionally, the board will continue to provide close oversight of the Organization and evaluate that oversight on a consistent basis.

Management of the Organization concurs with the audit finding. The Organization has provided increased training to the providers to ensure correct documentation is kept. The Organization has implemented a policy where providers are required to have a CACFP Binder where all required forms, including original enrollment forms and annual renewal forms, will be stored and must be available for review. Children with missing forms will have meal reimbursements disallowed until forms are completed correctly. These binders will be checked during the monitoring reviews.

We concur. According to previous findings, daily expenditures have been recorded into the general ledger as they occur and reconciled in a timely manner monthly. Adjustments will be recorded into the general accounting system daily, after a review by the Executive Director on completion of entries by the Office Manager. In corrective action steps already in place from the previous year’s findings, adjustments have been recorded in the general accounting system and accounts have been reconciled in a timely manner.

We concur. According to prior audit findings, the implementation of new accounting policies, including all expenditures, funds, and monthly bank statements, have been reviewed by the Executive Director and Office Manager in a timely manner. Since the previous year’s findings, all accounts have been reviewed and compared to the requested funding amounts, utilizing drawdown worksheets, two-person verification, and actual expenditure amounts entered within the accounting system. As a corrective measure, a printout from the accounting ledger page will be attached to each invoice or expenditure for comparison of the amount charged to the amount requested from each grant.

Internal Control over Compliance and Compliance with Cash Management Requirements  Contact: Chris Holmes   Title: Controller  Phone Number: 202-235-1938  Estimated Completion Date – ongoing  Corrective Action  During 2023, PSI refined its method for calculating drawdowns on federal awards that are near the end of the period of performance dates in response to the 2022-02 finding, however additional training with the Program Management Teams and cash projections is still ongoing in 2024.

Finding No: 2023-001 Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.498 Program: COVID 19 – Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Compliance Requirement: Activities allowed or unallowed/allowable costs Award Year: January 1, 2020 through December 31, 2022 (a) Criteria or Requirement 2 CFR 200.303 requires non-federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal control should include procedures to ensure federal expenditures are accurately and completely reported on the SEFA. (b) Condition Found The System did not have adequate controls related to determining allowability of expenditures for the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Grant. Our testing identified one charge within the population that had been charged incorrectly to the federal program. This charge was for government contract labor totaling $126,313 that was determined to be an unallowable expenditure that should have been removed prior to submission to the federal agency. In addition, during our testwork over expenses, we selected for testing a sample of 40 expenses charged to the program. One of our samples related to COVID lab tests was identified with a cost that should have been zero as the tests were voided and the vendor invoice reflected a zero balance; however, a standard test was inappropriately charged to the federal program in excess of the vendor invoice. Further, one sample was identified as having the incorrect price applied to the cost due to the drug being purchased from a different vendor, which had a lower price. This resulted in a higher price being charged to the federal program.The resulting impact of the above two items was $508 inappropriately charged to the federal program. In addition, the System was unable to provide evidence of management review and approval for three of the 40 expenses sampled. These three disbursements were for allowable costs under the terms and conditions of the program. (c) Cause The System’s review process in place over the recording of these costs did not operate effectively to prevent unallowable charges and inaccurate amounts from being submitted for reimbursement by the federal agency. The System was unable to provide evidence of certain management reviews and approvals due to system limitations that only maintain electronic approvals (via email) for 365 days. (d) Effect Federal funds were expended for unallowable purposes or for inaccurate amounts and evidence of the effective operation of management review controls was not maintained in accordance with Federal requirements. (e) Questioned Cost Expenditures related to contract labor and other costs of $126,821. (f) Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. (g) Repeat Finding in the Prior Year Not a repeat finding (h) Recommendation We recommend that the System strengthen controls over the management review process to prevent unallowable costs and inaccurate amounts from being charged to Federal programs. (i) View of Responsible Officials The Monthly Cost Capture detail for the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (ALN No. 93.498) reporting was developed to appropriately track expenditures that qualified under the grant. A wide variety of costs from across the company were charged to a COVID cost department. These costs originated in a variety of ways. While the overall amounts were tracked and reviewed, a comprehensive 100% review was not conducted. As a result, the government labor expenditure and the cost for a COVID lab specimen that spilled in transit were inappropriately included. Additionally, a higher cost per unit was used to allocate for a specific drug used by COVID inpatients. Furthermore, there were three Morris and Dickson invoices that were submitted to AP electronically approving payment via email, but the emails automatically delete after 365 days. (j) Corrective Action Plan The expenditures for the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (ALN No. 93.498) were reported through the PRF Reporting Portal using quarterly financial data. The portal restricted the entry of expenses up to the awarded amount plus interest earned. Consequently, we have sufficient expenses to cover any ineligible expenditures identified in this audit. As the program has concluded, no further actions are required for COVID drug and COVID lab test findings, as these were already accounted for in system reports that are now obsolete due to surpassing the Period of Availability dates. A new process will be implemented for manager sign-off on Morris and Dickson invoices submitted to AP electronically to ensure proper approval evidence is captured and documented correctly. Anticipated Completion Date: 6/30/2024 Name of Contact Person for Corrective Action: Sharon Nobles, Chief Financial Officer

CORRECTIVE ACTION PLAN The following is our response to findings in the audit as of December 31, 2023 FINDING 2023-001 - Uniform Guidance written policies and procedures During our audit, we discovered the City did not develop written procedures as required by the Uniform Guidance. Corrective Action Plan (CAP): 1. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The City Council will adopt written federal grant policies and procedures. 3. Official Responsible for Ensuring CAP: Nick Bishop, Finance Director, is the official responsible for ensuring corrective action. 3. Planned Completion Date for CAP: Fiscal year end 2024. 4. Plan to Monitor Completion of CAP: The City Council will be monitoring this corrective action plan. Sincerely, Nick Bishop City Finance Director 14

Implementing Improvement for Quarterly Reports – Epi and Lab Capacity (ELC) Contract with DSHS. -Weekly supervisor meeting for the Epidemiology Division. Data needed to complete the quarterly report is to be discussed at the end of the quarter. -The Associate Director for Disease Control and Prevention to meet monthly with the Epidemiology Division Manager on contract deliverables. -In addition to the activities in the Epidemiology Division, data needed from other divisions will be solicited by the Epidemiology Division manager within five days of the quarter end to include in the report. This includes employment status of employees funded by the contract via the position control report, and project activities related to the contract that should be included. -The Epidemiology Division Manager is to present the quarterly report to the Associate Director for review and approval before the report deadline. -The reports for the most recent 2 quarters, Sept through November 2023 and December 2023 through February 2024 were submitted by the due date. -The last two quarterly reports in the current cycle are due June 15, 2024 and August 15, 2024 (only covers two months).

Views of Responsible Officials and Planned Corrective Actions – We have since developed an organization policy for cash management for federally sponsored grant programs. SEH has provided and will continue to provide staff education on this policy in the future.

The School District should always reconcile its reimbursement requests with documented workpapers.

Management agrees with this finding. CASS does not have any subrecipients. However, if CASS has subrecipients in the future, comprehensive written policies and procedures will be in place to ensure all subrecipients payments are made on a timely basis and all required documentation and communications will be retained as result of missing or inaccurate information in the subrecipient’s drawdown requests prior to remittance.

Corrective Action Plan For the year ended December 31, 2023 Identifying Number: 2023-001 Finding: The overall process for tracking federal funds spent and the reimbursement process is a manual process performed by one department. The Foundation lacks formal policies for reimbursement and timely review of calculations throughout the year. Corrective Action Taken or Planned: Management is actively working with the awarding agencies to fully understand the compliance requirements and implement appropriate policy and process to administer the federal programs. Management is reviewing the current procedures and formalizing the process for tracking and reporting of federal funds. The responsible individuals for the plan are the Chief Executive Officer and Controller.

Management will have the employee responsible for the review of the LIHEAP Agency Invoice Reports sign each weekly report as approved.

Kid Power, Inc. agrees with the finding. The Organization will implement effective and written procedures for the review of cost allocation journal entries, allowable costs and activities, period of performance, 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 the Organization receives. Curtis Leitch, Deputy Director, 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. Procedures for internal controls include monthly expense reports completed through Brex by the Operations Manager, Charles Thomas, and stored in Kid Power, Inc.’s Google Drive; allowability and expense allocations will be reported in Google Drive on monthly basis and completed by the Deputy Director, Curtis Leitch; cost allocation journal entries will be inputted into QuickBooks on monthly basis by the Deputy Director, Curtis Leitch. Federal allocation and reimbursement reporting will be prepared by the Deputy Director, Curtis Leitch; reviewed by the Executive Director, Andria Tobin; and submitted by the Deputy Director, Curtis Leitch, on a quarterly basis.All reviews and approvals will be documented henceforth in Kid Power, Inc.’s Google Drive. Curtis Leitch, Deputy Director, will oversee the implementation of this corrective action.

Corrective Action Plan Marygrove Nonprofit Housing Corp II, dba McGivney Bethune Apartments Project No. 044-EE011 Year Ended December 31, 2023 June 20, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-002 – Replacement Reserve Withdrawals Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (CFDA# 14.157) Condition. Certain capital expenditures, amounting to $6,135, were requested and reimbursed from the reserve for replacements after already having been requested and reimbursed from the reserve. Management corrected this oversight and transferred the duplicate reimbursed funds from the Project's operating account to the reserve for replacements in May 2024. Effect. As a result of this condition, the reserve for replacements account was underfunded during 2023. Plan. Management agrees with finding 2023-002 and has developed the following plan. All invoices submitted for reserve disbursement requests will be compared to those on prior withdrawals. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: June 30, 2024

Action Taken: Management agrees with the finding and adopted the appropriate policies and procedures in December 2023.