Corrective Action Plans

AIRS in consideration to hired/promote staff to implement the segregation of duties as the organization grows to meet and achieve at present to obtain the benefits in improving duties. AIRS will create or expand written policies and procedures covering items including bank reconciliation, payroll, journal entries and other financial review to insure proper segregation and controls

Deficiencies in controls surrounding the cash management and program income. A. Name of contact person responsible for corrective action: Name: Courtney Bershell Title: Business Manager B. Corrective action planned: The district will implement changes to ensure child nutrition management software be used to document and support the daily meal counts that will be used for claim reimbursements. C. Anticipated completion date: June 30, 2024.

We agree with the finding that the same expenditures were included in reimbursement requests for assistance listings 21.023 and 14.231. The reimbursement requests were compiled using a separate database of individual clients for each assistance listing. Due to a data entry error, the same expenses were included in both databases. As part of CAC's internal controls, the databases are supposed to be reconciled to the appropriate expenditure accounts of the general ledger for each assistance listing. This reconciliation did not occur for these reimbursement requests. When Management reviewed the reimbursement request prior to submission, that review compared the reimbursement request to the database listing and not the general ledger. The following corrective action plan will minimize the occurrence of reimbursement being requested from multiple grantors for the same allowable expenditures. Beginning in the FY2025 fiscal year, invoices that are submitted to CAC management for review that are based on worksheet or database listings will be accompanied by a copy of the general ledger and amounts shown on the database or worksheet reconciled to the general ledger. The projected date for full implementation of the corrective action plan for this finding is June 30, 2025. The contact person for this corrective action are: Barbara Kelly, Executive Director, David Mincey, CAC Fiscal Services Manager/Internal Auditor, CAC Chief Financial Officer, to be selected.

The Univesity implemented a comprehensive ERP software tool, Ellucian Colleague in FY2021 and FY2022 and hired more staff. The built-in internal control structure, which includes access to enrollment reports and data coupled with a complete reconciliation process with the Office of Financial Aid, Office of the Registrar and Student Account wills prevent this from recurring.

FINDING 2022-004 Finding Subject: CDBG – Entitlement Grants Cluster—Reporting Summary of Finding: Condition and Context: The County did not have internal control procedures over the Quarterly Reports (PR29), IDIS Section 3 Performance Report, and NSP Quarterly Reports. One individual prepared or generated the report without a review or oversight process. Additionally, the County’s internal controls were not consistently documented over the draw down requests for the CDBG grant during the audit period. The draw down requests were entered into IDIS, which then becomes the basis for several of the reports. The control presented by the County was that one individual prepared and entered the request, which would then be printed, and another individual would review and sign the printed request to document the review. Of the thirteen reimbursement requests tested, control documentation for eight of the requests were printed and signed during current period, after the documentation was requested. The creation of documentation of the control procedure did not support that internal controls were effective during the audit period. Recommendation: We recommended that the County's management design and implement a proper system of internal controls, and retain documentation of its system of internal controls, to ensure compliance with reporting requirements. Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 and brownta@lakecountyin.org Views of Responsible Officials: LCCEDD concurs with the audit finding. Concurrence: The Fiscal Officer from the Audit Period was new to the position and her training was focused on the changes to the financial systems at the county over the DRGR quarterly reporting of NSP actions. Further, Finding 2022-003 also caused some of the reporting issues with CDBG of having two CDBG funds and posting errors to these funds. The current LCCEDD Fiscal Officer found the problems during the audit and corrective actions were done retroactively to address this part of the finding with the drawdown requests. The CDBG drawdowns were submitted into IDIS by the Fiscal Officer who printed out the drawdown request. These printouts were then given to the Executive Director or the Deputy Director who then went into IDIS and approved the drawdown request, then print out the IDIS drawdown approval and return the request and the signed approval back to the Fiscal Officer. LAKE COUNTY COMMUNITY ECONOMIC DEVELOPMENT DEPARTMENT 2293 N. Main Street - Crown Point, In 46307 Tel. (219) 755-3225 www.lakecountyin.org INDIANA STATE BOARD OF ACCOUNTS 38 Description of Corrective Action Plan: LCCEDD staff have already adopted changes in internal controls to correct the CDBG reporting deficiencies as described in Finding 2022-003. Further, management will oversee compliance with current policies and the new quarterly reconciliations. LCCEDD policies will be updated to make the following changes: General Management and Oversight: On an on-going basis, the Director will meet with Department staff to determine if training or technical assistance is needed to complete HUD reporting requirements in a timely and accurate manner. NSP Quarterly Reports: To be followed until the HUD field office indicates QPR reports are no longer needed due to grant closeout: 1. Before the close of each month, the Fiscal Officer will create receipts and draws as needed in HUD’s DRGR system to reflect funds receipted or expended by the County. 2. At the close of each quarter, the Fiscal Officer will prepare and submit the quarterly report in DRGR for the NSP1 and NSP3 grant allocation. To prepare the report, the Fiscal Officer will reconcile all expenses and receipts posted in the County’s general ledger system for the NSP programs with the receipts and drawdown requests recorded in in HUD’s DRGR reporting system. 3. Before submitting the NSP QPR Report in the DRGR system, the Deputy Director will review and approve the prepared reconciliation and QPR Report. Any discrepancies between the two systems will be reported to the Auditor and the Department Director to determine corrective actions. 4. Within 30 days of the close of each calendar quarter, the Fiscal Officer will submit the NSP QPR Report via DRGR. The Fiscal Officer will maintain a copy of the NSP QPR and the corresponding reconciliation in their program files. Cash on Hand Reports: 1. At the close of each quarter, the Fiscal Officer will prepare and submit the Cash on Hand Report within thirty days of the close of the quarter. The Fiscal Officer will reconcile all expenses and receipts posted in the County’s general ledger system with the receipts (report PR09) and drawdown requests (report PR07) in HUD’s IDIS Online reporting system. 2. Before submitting the Cash on Hand Report in the IDIS Online system, the Deputy Director will review and approve the prepared reconciliation and Cash on Hand Report. Any discrepancies between the two systems will be reported to the Auditor and the Department Director to determine corrective actions. 3. Within 30 days of the close of each calendar quarter, the Fiscal Officer will submit the Cash on Hand Report via IDIS Online. The Fiscal Officer will maintain a copy of the Cash on Hand report and the corresponding reconciliation in their program files. INDIANA STATE BOARD OF ACCOUNTS 39 Section 3 Reporting: 1. As part of the application review, the Deputy Director will determine the applicability of the Section 3 requirements for each proposed project. 2. For projects where Section 3 is applicable, the Deputy Director will ensure that staff administering the project are familiar with the Section 3 requirements and understand the forms and reporting required to properly report Section 3, including the determination of total labor hours worked, labors hours worked by Section 3 and Targeted Section 3 workers, and corresponding certifications. 3. The County will collect Section 3 reports from subrecipients administering projects throughout the period of performance. If the project meets Section 3 benchmarks, the County will consider the activity to be in full compliance with Section 3. If the project does not meet one of the Section 3 benchmarks, the County will require reporting on the qualitative efforts that the subrecipient made to try to reach the benchmarks. 4. Section 3 information collected for each project will be reported in IDIS Online. The Section 3 information must be reported annually before the submission of the annual report (CAPER) to HUD. Anticipated Completion Date: Part of the corrections have already been put into place and the Policy and Procedure Manual will be amended in April of 2025 after the Lake County Redevelopment Commission adopts appropriate changes.

FINDING 2022-003 Finding Subject: CDBG – Entitlement Grants Cluster—Program Income Summary of Finding: Condition and Context: The County received program income through various loan programs it offered to qualifying individuals. Once the County received a loan payment, the receipt was posted into the financial accounting system of the County and recorded in a grant fund. The amount received was also to be recorded in the Department of Housing and Urban Development’s (HUD) Integrated Disbursement & Information System (IDIS) website. The recorded program income in IDIS would then appear on the Drawdown Report by Voucher Number report (PR07). No internal control process had been established over the program income compliance requirement. One individual was responsible for notifying the Auditor's office when program income money was received, in order for it to be receipted in the County’s financial accounting system. The same individual was also responsible for reporting the same on IDIS site. No controls were established to ensure the program income that was recorded in the financial accounting system was also reported on IDIS site and the PR07 report. Additionally, four receipts totaling $38,960 were selected for testing from the County’s receipt ledger. These four receipts were unable to be located on the PR07 report provided for audit. One of the four receipts was recorded in the IDIS system after information regarding the receipt was requested. The receipt was not in the PR07 report that had been provided for audit when we were provided information documenting it being recorded in IDIS. Furthermore, we were unable to verify the total amount recorded in receipt ledger to the total reported on PR07 report. The County’s ledger was greater than the PR07 report by $30,324 and is primarily attributed to under reporting of program income in IDIS as identified above. Recommendation: We recommended that the management of the County establish a system of internal controls to ensure that all program income received is properly reported in the IDIS system and expended prior to drawing down federal awards. Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 and brownta@lakecountyin.org Views of Responsible Officials: LCCEDD concurs with the audit finding. LAKE COUNTY COMMUNITY ECONOMIC DEVELOPMENT DEPARTMENT 2293 N. Main Street - Crown Point, In 46307 Tel. (219) 755-3225 www.lakecountyin.org INDIANA STATE BOARD OF ACCOUNTS 36 Description of Corrective Action Plan: LCCEDD staff have already adopted changes in internal controls to correct the Program Income reporting deficiencies. The process is as follows: 1. All incoming checks into the department are first reviewed by the Deputy Director. The Deputy Director determines the source of income (i.e. CDBG, HOME, NSP) and the correct receipt type (program income, repayment, homebuyer). The Deputy Director records the IDIS number of the project on the check before giving it to the Fiscal Officer. 2. The Fiscal Officer records the receipt on an internal schedule of receipts and submits the check to the County Auditor with the check deposit form with the IDIS number and correct fund and account number for deposit. 3. Once the County Auditor posts the receipt to the County’s general ledger, the Fiscal Officer records the Auditor’s receipt into HUD’s IDIS Online reporting system. 4. At the close of each quarter, the Fiscal Officer will prepare and submit the Cash on Hand Report within thirty days of the close of the quarter. The Fiscal Officer will reconcile all expenses and receipts posted in the County’s general ledger system with the receipts (report PR09) and drawdown requests (report PR07) in HUD’s IDIS Online reporting system. Before submitting the Cash on Hand Report in the IDIS Online system, the Deputy Director will review and approve the prepared reconciliation and Cash on Hand Report. Any discrepancies between the two systems will be reported to the Auditor and the Department Director to determine corrective actions. 5. Within 30 days of the close of each calendar quarter, the Fiscal Officer will submit the Cash on Hand Report via IDIS Online. The Fiscal Officer will maintain a copy of the Cash on Hand report and the corresponding reconciliation in their program files. 6. On an on-going basis, the Director will meet with Department staff to determine if training or technical assistance is needed to complete HUD reporting requirements in a timely and accurate manner. Anticipated Completion Date: A policy and procedure amendment will be written by the end of this year and presented to the Lake County Redevelopment Commission for their March 2025 meeting for adoption.

Recommendation: The Association establish controls that allow for the timely and accurate recording of grants and contracts receivable from reimbursement-based awards in the same period as their corresponding expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Containment Through this audit process and staff turnover, tasks have been distributed and processes have been implemented immediately to meet the expectations that an AR transaction be entered into the fiscal system within a timely manner of one week or sooner. Root Cause Due to a lack of knowledge of the new software system. Not all information was migrated into the new software system in a timely manner, making it difficult to use at its full potential. OCCDA had a large turnover in the fiscal team during the audit process. The transition to the new fiscal software was during the height of the COVID-19 pandemic, making it difficult to complete training and migration of the new system. Action Taken Immediately in 2023, the fiscal team implemented adding reports/documentation to all requests for funding to allow for better tracking and record keeping. Newly hired staff have established a clear understanding of the naming conventions for clarity and accurate reporting. Tasks have been realigned to specific positions so that all duties are covered and responsibilities are defined. This will ensure that all fiscal tasks are completed timely and accurately establishing controls for reimbursement funding. Training has been provided for the fiscal team on the internal processes and procedures to ensure the timely entry of all data and the importance of accurate monthly reports. We have reorganized the chart of accounts in support of the software consultants, we have added additional program numbers to track grants separately by funding year to allow us to close each grant yearly. Our Fiscal Assistant has been trained to complete all accounts receivable. Receivable billings are completed in the month that they are performed. All receipts are recorded in the month they are received. Monthly reports continue to be sent out each month for the Leadership team to review, allowing for transparency and additional reviews and accuracy. Name(s) of contact person(s) responsible for corrective action: Fiscal Manager Planned completion date for corrective action plan: Completed

Recommendation: The Association continue to work internally and with software vendors and outside consultants as needed to implement a chart of accounts and custom reporting tools that will assist them in complying with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Containment Upon discovering flaws in the new financial system we immediately hired a third-party consultant who was experienced with our newly implemented software system (MIP) as well as fiscal best practices. This consultant was made available to the Fiscal team at the time, offering support in the transition to the new software. Root Cause Not all information was migrated into the new software system in a timely manner, making it difficult to use at its full potential. OCCDA had a large turnover in the fiscal team during the audit processing, making it difficult to find information or pull reports that were not fully migrated. The transition to the new fiscal software was during the height of the COVID-19 pandemic, making it difficult to complete training and migration of the new system. Action Taken Immediately, the OCCDA Executive Director worked directly with the remaining team members to ensure business continuity in the fiscal department. Promptly, the chart of accounts was updated to track grants separately as well as any carry-over funds. Also, an additional support membership was purchased through NP Solutions which specializes in MIP implementation and software. During the recruitment and hiring of staff, the new Fiscal/HR Director has delegated tasks that streamline duties, creating separation of duties where appropriate to ensure effective internal controls. The fiscal team positions have not only been delegated separate tasks but have also been provided in-depth training on them. The leadership team has been trained on allowable costs and charged with reviewing their assigned budgets each month. Already our Fiscal Manager has implemented running monthly spending reports. The Leadership team members work monthly with the Fiscal Manager to review the reports and line-by-line reports when appropriate to seek clarification and ensure that we are reporting accurately. The Fiscal/HR Director, Fiscal Manager, and Fiscal Assistant were sent to an in-depth MIP training this year to increase skills and knowledge of software to align with GAPP practices. Also, the Fiscal/HR Director has completed a Uniform Guidance training this year and our Fiscal Manager will be taking this training in the coming year. Moving forward in 2024, the Fiscal Manager will continue to update the chart of accounts to organize the general ledger and enhance our reports for ease of use and ensure accuracy. On or before March 2024 the chart of accounts will be updated. For example, each time a new funding source is received a new program code will be created allowing for tracking and reporting. Our internal policy indicates that we will have regular reviews and ensure compliance. Our new Fiscal Manager has current relationships with the software team allowing for questions to be asked and answered quickly. We are continuing to work with software consultants closely in updating the usability of our software and correcting our mapping of GL accounts. We have reorganized the chart of accounts in support of the software consultants, we have added additional program numbers to track grants separately by funding year to allow us to close each grant yearly. This will allow us to process reports by funding source by year/grant. Name(s) of contact person(s) responsible for corrective action: Fiscal Manager Planned completion date for corrective action plan: In process to be completed by March 2024 (Q1)

Finding 2022-001 “Document Policies and Procedures Over Federal Awards” Correction Action to be taken: We have been updating and developing written policies and procedures related to Federal awards as required under Uniform Guidance. Expected Completion Date: We anticipate that the policies and procedures will be completed and approved by June 30, 2025. Contact Person: Julie Hebert, Finance Director

Finding 2022-013 U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083, Award Number EMW-2019-FF-0819 Management’s Response: Management agrees spend controls are an important part of grant compliance. Management continues to improve compliance and controls over awards to ensure compliance. In 2023 we converted to a new ERP system and part of the conversion was implementing spend controls to aid in compliance for awards to minimize future issues. Views of Responsible Officials and Corrective Action: Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Views of Responsible Officials The Organization agrees with this finding. Corrective Action Plan The Organization has strengthened its internal controls over non-payroll transactions such that all expenditures can be properly explained with supporting documentation, and all expenditures are reviewed and approved prior to payment. Additionally, the Organization only submits expenditures for reimbursement that have been paid. While the Office of Management and Budget allows the reimbursement of expenditures that have been incurred, the pass-through entity will only reimburse expenditures that have been paid. Name(s) of Responsible Individuals Lacy Kimes, Board President Anticipated Completion Date Already implemented.

Credit Balances and Heightened Cash Monitoring 2 (HCM2) Compliance Planned Corrective Action: Southwestern Christian University will provide ongoing training to current staff as well as new staff on HCM1 and/or HCM2 compliance regulations with the Department of Education. SCU will have additional staff review student accounts for credit balances that would result from disbursements of Title IV Aid. Person Responsible for Corrective Action Plan: Rita Palmer, Director of Financial Aid Anticipated Date of Completion: Immediately

Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Southwestern Christian University will designate multiple staff to oversee the guidelines and disbursements of all federal money. The Interim CFO is responsible for the reconciliation of expenditures and drawdowns from any future federal funds. Person Responsible for Corrective Action Plan: Bill Martin, Interim CFO Anticipated Date of Completion: Immediately

Finding No. 2022-004 We agree and acknowledge the identified discrepancy in Finding No. 2022-004. However, we clarify that drawdowns were not higher than actual expenditures. The variance was due to timing differences between the reporting of cumulative expenditures on SF-425 reports and the figures in our accounting records. To address this, while the findings pertain to FY 2022, we have taken corrective actions that can be seen in FY 2025: 1. Change in Responsible Personnel: In FY 2025, we assigned a new team to manage the cash management process. This change brings greater accountability and expertise to ensure accurate alignment of federal grant drawdowns with actual recorded expenditures. 2. Enhanced Year-End Closing Procedure: In FY 2025, we introduced a robust year-end closing procedure to ensure that expenditures reported in our grant documents are aligned with actual allowable costs as per our accounting records. This process helps ensure consistency between our SF-425 reports and internal records. 3. Stricter Monitoring and Internal Controls: We have strengthened monitoring and internal controls in FY 2025 to ensure that future drawdowns strictly adhere to our reimbursement policy. This includes closer oversight of cumulative expenditures to prevent any variance between reported and actual expenditures. Implementation Timeline: These corrective actions, implemented in September 06, 2024, are designed to prevent similar issues from arising in future audits and ensure full compliance with federal grant reporting requirements. Responsible person: Arlene DeleonGuerrero, CFO

Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend management implement a review process to check individual's compensation charged to federal grants against annual federal limitations prior to drawdown of funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement review processes to identify individuals over federal wage limitations moving forward before being charged to federal grants. Name(s) of the contact person(s) responsible for corrective action: Duke Fokuo Planned completion date for corrective action plan: December 2024

Health Centers Cluster – Assistance Listing No. 93.2242/93.527 Recommendation: We recommend reviewing reconciliation procedures between detailed grant expenditures and summary schedules used in reporting/draw down requests to ensure sufficient detail to support draw downs. Also recommend a detailed review and approval process for federal grant eligible expenditures and draw downs, to identify issues prior to draw down or reporting in the future. Documentation should be retained to support review/approval occurrence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review and improve reconciliation and review process around eligible expenditures for federal grants, and drawdowns of federal funds. Name(s) of the contact person(s) responsible for corrective action: Duke Fokuo Planned completion date for corrective action plan: December 2024

Pulaski County will review the recommendations as presented and work to adjust internal controls to prepare SEFA information in accordance with the recommendations of the auditor.

Finding 2022-003: Reconciliation of Accounts Federal Program: Research and Development Cluster (Education and Human Resources)Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022) Condition: The year-end schedules for federal grants receivable, net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 10/15/2024 Responsible Official: Michael Brosnan, CFO

Management will undertake the following corrective actions to address the material weakness identified: 1.Provide additional training to staff involved in payroll processing. 2.Establish procedures and implement more precise controls to ensure that expenditures are properly reviewed and approved before being charged to a federal award.

Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Management). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Condition. Throughout the period of the grant, the Organization requested drawdowns of federal funds from the grantor in excess of their immediate needs and in excess of grant expenses incurred. Effect. The Organization received federal funds in excess of their immediate needs and in excess of the total amount expended. Upon discovering this error, and after consulting with the U.S. Department of Education, the Organization returned $154,615 to the grantor on November 4, 2022 and $75,167 on March 20, 2023. Corrective Action Plan. A policy around federal programs has been created and will be implemented for all future federal grants, which includes cash management to ensure funds drawn down are not in excess of need and amount expended. Contact Person Responsible. Alison Polidano Anticipated Completion Date. September 15, 2024

Panthera implemented an approval workflow in Chrome River, but we will also ensure a formal written approval is issued on quarterly expenditure reports going forward.

The Uniform Guidance required that a grantee must establish and maintain records adequately reflecting the source and application of funds with information including authorizations, unobligated balances, expenditures, and income and that these be supported by source documentation that must be retained for three years from the final expenditure report. Requests for reimbursement and their supporting information could not be located for three of six reimbursement requests. We recommend that a standardized file and documentation system be implemented for all grant reimbursement requests containing the reimbursement request with evidence of review and authorization and including the supporting expenditure reports. Views of Responsible Officials and Planned Corrective Actions: The Academy has contracted with an accounting and administrative contractor who has implemented a recordkeeping system for grant reimbursement requests and related supporting documentation.

here was inadequate oversight of activities and information provided by the contractor resulting in a material overstatement of meals claimed for the current year. Sufficient controls were not in place for the current fiscal year to ensure that an accurate meal count was claimed for USDA reimbursement. We recommend that a knowledgeable person be assigned responsibility for oversight of the child nutrition program. We further recommend procedures be implemented to provide oversight of contractor services and information provided including a review process for the USDA claims requests. Views of Responsible Officials and Planned Corrective Actions: The Academy has employed a supervisor responsible for overseeing the child nutrition program and the contract with the previous provider has terminated. Further, the Academy currently provides onsite meal service beginning with the 2022-23 school year provided by a new contractor.

ACL Centers for Independent Living – Assistance Listing No. 93.435 Type of Finding: Allowable Activities and Allowable Costs – General Disbursements • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.303, non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues regulations, and the terms and conditions of the Federal award. Condition: Documentation not maintained to support one cash disbursement. Questioned costs: None Context: 1/40 of the general disbursements tested lacked indication of approval. Deemed to be an isolated incident as the vendor in question provides physical receipts to DEC, which is an unusual and infrequent method. Limited transactions with said vendor. Cause: Vendor purchases are in-person and physical receipt is obtained. This is unusual for common vendors used and leads to more opportunity for documentation loss. Effect: Reimbursement requests could be made for unallowed expenditures. Repeat Finding: No Recommendation: Review document retention process to ensure all costs that are charged to a federal program are adequately reviewed and documentation of that process is maintained. If documentation is not available, costs should not be charged to the Federal program. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: This was an isolated incident and DEC now takes steps to digitally record physical receipts with a photograph as soon as possible. Name(s) of the contact person(s) responsible for corrective action: Kimberly Meck, Executive Director Planned completion date for corrective action plan: Already implemented.

ACL Centers for Independent Living – Assistance Listing No. 93.435 Type of Finding: Cash Management • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.302(b)(3) the nonfederal entity must keep "records that identify adequately the source and application of funds for federally funded activities" and must maintain effective controls over these procedures. Condition: No accompanying invoices to support drawdown requests. Questioned costs: None Context: While there existed evidence of supporting invoices for Federal expenditures (with the exception of one item for $52 - see finding 2022-006), these were not compiled into an auditable list showing justification for the drawdown amounts. Auditors reviewed the profit and loss schedule for the year and were not able to identify a clear pattern between expenditures and drawdowns. Cause: Lack of procedures requiring supporting documentation. Effect: Reimbursement requests could be made for unallowed expenditures. Repeat Finding: No Recommendation: Implement process to ensure documentation is kept identifying which expenditures are included in reimbursement request. There should be a secondary individual (ED and contract accountant) involved in the process to ensure accuracy - documentation of the two-person preparation and review process should be documented. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: DEC’s new contract accountant provides a twolevel review process for DEC accounting including review and documentation for drawdowns. Name(s) of the contact person(s) responsible for corrective action: Kimberly Meck, Executive Director Planned completion date for corrective action plan: Already implemented.