Corrective Action Plans

Finding: 2022-001 Material Weakness in Internal Control over Financial Reporting and Compliance Personnel Responsible for Corrective Action: Kerry Romero, Director of Accounting Anticipated Completion Date: December 31, 2023 Condition: During our testing, we noted reimbursement requests were prepared using grant budgets rather than direct costs incurred. Management was unable to determine direct costs related to general and payroll disbursements. As a result, proper revenue recognition could not be determined for financial reporting purposes. Corrective Action Plan: The Organization will use the jobs and classes functions within their accounting software to track expenses related to grants. The Organization hired a Grant Coordinator to oversee the review, tracking, and reporting for all grants. The Organization will train and work with all applicable staff to create timesheets for grants requiring such documentation. The Organization will prepare a Schedule of Expenditures of Federal Awards (SEFA) which will be used in conjunction with the accounting software to track grant costs.

Finding 2022-003 - Special Provisions and Testing - Residual Receipts Account Federal Agency Name: US Department of Housing and Urban Development Program Name: Supportive Housing for Persons with Disabilities CFDA #: 14.181 Finding Summary: The corporation did not deposit project funds in a federally insured account within 60 days of fiscal year end. Responsible Individuals: Mary Simonson, Executive Director Corrective Action Plan: Management agrees with the finding and will review their internal control over compliance related to the program's residual receipts amount to ensure the excess operating funds be deposited in the fund account within 60 days following the end of the fiscal year. Anticipated Completion Date: Fiscal year 2023

Finding 2022-001: Internal control deficiency and noncompliance over the calculation of lost revenues attributable to coronavirus. Condition: Emanate Health and Affiliates incorrectly reported lost revenues attributable to coronavirus in the HRSA PRF Reporting Portal (the ?Portal?) due to errors made in the calculation of lost revenues which resulted in an overstatement of lost revenues of $8,123,440. Planned Corrective Action: In future reporting periods, management will add an additional layer of review of the lost revenue calculation before submission through the Portal. Through this review, management will ensure the lost revenue calculation is performed on a comparable basis which would include the same types of revenues being compared. Management will correct the lost revenues attributable to coronavirus in the next Portal submission, as applicable and ensure any other Portal submissions have the correct lost revenue calculation and is reported correctly. Contact Person: Leon Choiniere, Chief Financial Officer Anticipated Completion Date: September 29, 2023

Millsap ISD will implement a system of internal controls to mitigate the possibility of claim duplication for all federal funding sources. The following are the steps Millsap ISD will implement. ? The CFO will keep track of expenses in all federal funds and will submit for reimbursement every quarter. ? Prior to requesting reimbursement, the CFO will print a year-to-date report from Ascender demonstrating quarterly expenses minus prior reimbursements. ? The total expense report, utilized to verify request for reimbursement, will be confirmed by the CFO and Assistant Superintendent with signatures, dates, and times. ? Upon verification, the CFO will request federal reimbursement. ? After receiving and posting requested funds, the CFO will compare expense and income on the as of date to confirm that more income than expenses have not been submitted for reimbursement.

Millsap ISD will implement a system of internal controls to mitigate the possibly of claim duplication. The following are the steps Millsap ISD will implement. ? The Director of Child Nutrition will run the Monthly Claim report for each campus and a summary of the district for the month. ? The Director of Child Nutrition will review these reports for unreconciled meals, missing data, and possible errors. ? After review of the reports, the Director of Child Nutrition will enter the claim data by site, based on eligibility in TX-UNPS as it is reported in the Point of Sale (POS) system. As the Director of Child Nutrition enters and verifies the data for each site in the TX-UNPS claim system, the data is aggregated and will be verified for accuracy to the district summary report from the Point of Sale. ? The monthly claim report for the POS system will be printed, and attached to the claim for reimbursement summary showing site details from the TX-UNPS claim system. ? The Director of Child Nutrition will verify that the data entered for the Claim for Reimbursement match the data from the monthly claim report and sign off with date and time that it is correct. ? This document will be given to the CFO, who will verify it as well with signature, date, and time. ? If discrepancies are found, a revised claim may be filed with the state within 60 days of the last day of the claimed month.

Re: 2022-003 - Significant Weakness - Education Stabilization Fund The District is choosing not to draw down any of the Esser II funds until after recommendation from the District's consultants and Wyoming Department of Education are finalized. The District is in the process of implementing a new accounting software. The new software will allow us to establish strong monthly grant cash drawdowns and reconciliations. Cross training will be implemented with all team members in the Business Office so the continuity will be preserved no matter the staffing configurations. Respectfully, Connie Gay

Finding Number: 2022-004 Condition: We noted during testing that one draw request was made prior to the expenditures being incurred. Planned Corrective Action: The accounting function for GCCARD transitioned to the Office of Fiscal Services in August of 2022. From that point forward accounting staff were trained that draw requests were to be made after allowable expenditures were incurred. Contact person responsible for corrective action: Chrystal Simpson, CFO Anticipated Completion Date: 10/01/2022

Finding: 2022-001 Financial Reporting for Claim Reimbursement Our auditors identified that internal controls were not present to prevent incorrect claim submissions. Responsible Individual: Jen Pearson, Executive Director Corrective Action Plan: Management agrees with the finding, has reviewed procedures with the appropriate personnel. Date of Completion: June 30, 2023

CAP for Finding: 2022-304 DATE: March 23, 2023 TO: Carolyn Stittleburg, Deputy State Auditor Legislative Audit Bureau FROM: Barry Kasten, Director Bureau of Fiscal Services Department of Health Services SUBJECT: Corrective Action Plan ? Coronavirus State and Local Fiscal Recovery Funds ? Monitoring of Local and Tribal Health Department Response and Recovery Support Program Expenditures Department staff has reviewed the Legislative Audit Bureau?s (LAB) interim audit memo for Finding 2022-304: Coronavirus State and Local Fiscal Recovery Funds ? Monitoring of Local and Tribal Health Department Response and Recovery Support Program Expenditures. This is the department?s Corrective Action Plan. ? Recommendation (2022-304): Coronavirus State and Local Fiscal Recovery Funds ? Monitoring of Local and Tribal Health Department Response and Recovery Support Program Expenditures We recommend the Wisconsin Department of Health Services: ? Develop and implement written policies and procedures for the review and tracking of the quarterly reports used to monitor expenditures under the Local and Tribal Health Department Response and Recovery Support program. Wisconsin Department of Health Services Planned Corrective Action: As beneficiaries, the Treasury Guidance indicates that Local and Tribal Health Departments are not subject to subrecipient monitoring and reporting requirements. The designation of beneficiary is unique to the CSLFRF and thus is not as familiar to DHS as the subrecipient designation and subsequent reporting requirements. The uncertainty surrounding this designation resulted in DPH not following the best practices described in the DPH Contract Management Manual. DPH?s Contract Management Manual outlines requirements and best practices for contract management. This Manual describes how to best review and track expenditures to monitor expenditures. The Manual encourages the best practice of requesting enhanced expenditure reporting from agencies, in addition to the reporting required for CARS payments. The Manual describes the role of the contract administrator in reviewing the expenditure information against the approved budget to ensure expenses are reasonable and allowable. The Manual also suggests maintaining copies of submitted reports and verifying the amounts in the submitted reports correspond to CARS reports. Examples of expenditure tracking are provided as is a description of how this tracking and other fiscal monitoring supports bureaus within DPH and DHS. DHS will review the existing policies and procedures in the Contract Management Manual to ensure that the level of detail is sufficient to prevent further non-compliance. We recommend the Wisconsin Department of Health Services: ? Maintain the quarterly reports, document its review of the quarterly reports, and document its correspondence with the public health departments regarding resolution of reporting variances. Wisconsin Department of Health Services Planned Corrective Action: DPH hired a position in June 2022 to manage and track expenditures and reporting for its Coronavirus State and Local Fiscal Recovery Funds granted to locals and tribal public health departments. DPH will continue to review, track, and maintain quarterly reports, and document correspondence with the local and tribal public health departments per best practices in the DPH Contract Management Manual. We recommend the Wisconsin Department of Health Services: ? Review the contracts with the public health departments and determine whether any revisions are needed to clarify expectations for documentation and timeliness of filing the quarterlyreports; and Wisconsin Department of Health Services Planned Corrective Action: DPH will review its contracts with the local and tribal public health departments and ensure timely filing of quarterly reports. Specific areas of non-compliance have been identified and division staff will review and draft updated scope of work language to mitigate delays in reporting from our local partners. We recommend the Wisconsin Department of Health Services: ? Ensure it obtains quarterly reports to support the payments it made to the City of Milwaukee Public Health Department. Wisconsin Department of Health Services Planned Corrective Action: DPH has now obtained quarterly reports from the City of Milwaukee Public Health Department and is in the process of reviewing them. Division staff will work with the City of Milwaukee Health Department to ensure future compliance. Anticipated Completion Date: June 30, 2023 Person responsible for corrective action: Karen Drogsvold, Budget Section Manager Division of Public Health, Bureau of Operations karen.drogsvold@dhs.wisconsin.gov

Adjusting Journal Entries, Required Disclosures and Draft Financial Statements Auditor?s Recommendation: Although auditors may continue to provide such assistance both now and in the future, under this pronouncement, the District should continue to review and accept both proposed adjusting journal entries and footnote disclosures, along with the draft financial statements. School District?s Response: Adam Moate, Business Manager, has received, reviewed and accepted all journal entries, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information for the year ending June 30, 2023 and in future years. Further, the District believes it has a thorough understanding of these financial statements and the ability to make informed judgments based on these financial statements. Lastly, the District considers such assistance provided by the auditors to be the most cost effective in preparing such information.

Client response and corrective actions ? The City of Missoula finance department agrees with the auditors recommendations for changes in procedures. The City will implement additional reviews to ensure that reimbursement requests match underlying invoices as well as the financial accounting software prior to submission to the state. These reviews will happen quarterly.

Finding Number: 2022-004 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 14.231 Emergency Solutions Grant Program Name of Contact Person Responsible for Corrective Action: George Hardgrove, EGCI Service Team Controller Corrective Action Planned: Ramsey County had exceptions for 6 of 40 transactions tested. The exceptions noted were for a lack of receipt copies and not having the proper payroll reports attached. We agree with the lack of receipt copies. For payroll, we felt the payroll reports provided were adequate to determine the appropriate labor cost. The receipt issue came to about 2.5% of the $5.5M that was expended under this award in 2022 while the payroll documentation was about 7% of this amount. Nonetheless, we will create and use a check list to ensure we have the proper receipt copies and payroll reports for each subrecipient invoice we approve. We will also work on clarifying the required payroll reports with our grantors. Anticipated Completion Date: December 31, 2023.

Small Business Administration Naples Players, Inc. respectfully submits the following corrective action plan for the year ended April 30, 2022. Audit period: May 1, 2021 ? April 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-004 Shuttered Venue Operators Grant ? Assistance Listing No. 59.075 Recommendation: We recommend company credit cards are not used for personal expenses. If a company credit card is used in error, the transaction should be recorded to a liability account to ensure reimbursement from the employee. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Qualified finance staff in place to oversee and record properly. Implementation of new credit card system (divvy.com) that allows improved oversight of spending and budgets. Name(s) of the contact person(s) responsible for corrective action: Kenzie Currie Planned completion date for corrective action plan: February 2023

2022-001 Compliance and Internal Controls over Cash Management (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425E ? COVID-19 Student Portion Recommendation: While not applicable for HEERF funding since this has been fully utilized, for all related federal awards to students, we recommend that in order to minimize the time between funds drawn and eventual disbursement to students, the Business Office should only make draws after communication from the Student Financial Aid department that all student reviews have been completed and these are ready to be paid. Evidence of this communication should also be maintained to allow for proper audit trail. Corrective Action: The College will implement procedures related to federal awards to students that includes the authorization for draws only after formal written communication from the Student Financial Department that all student reviews have been completed with written authorization that they are final and ready for payment. Responsible Parties: A. Benjamin Chelladurai, VP/CFO and Dr. Lisa Stewart, VP/Director of Financial Aid Date Corrected: This recommendation was implemented with immediate effect.

Saranac Community Schools Corrective Action Plan For the Year Ended June 30, 2022 Saranac Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit Period: June 30, 2022 District responsible individual to implement this plan: Jammie Sprank, Finance Director The findings from the June 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding: Financial statement audit Finding 2022-001 ? Significant Deficiency Recommendation: The District should monitor revenues more closely and adjust food service program to match revenues. Management should complete the planned expenditures needed to maintain acceptable fund balance. A spend-down plan should be developed and followed to reduce fund balance below acceptable levels. Planned Corrective Action: Management agrees with the finding and we are in the process of developing a spend down plan. The spend down plan will include completion of the fixed asset purchases and other upgrades to equipment. Management is looking at changing food choices including increasing healthy food options as a means of matching expenditures with revenues. Planned Completion Date: The District's spend down plan is anticipated to be completed by June 30, 2023. Kitchen equipment availability is severely limited due to national supply chain delays. The installation of some equipment may be limited to times when school is not in session. Due to this the District may not complete the spend spend down by June 30, 2023.

See Corrective Action Plan for chart/table

Views of Responsible Officials and Planned Corrective Actions - SoutheastHEALTH ("SEH") has developed an organization policy for cash management for federally sponsored grant programs. SEH will generally use the reimbursement method unless there is an immediate cash need to minimize the time elapsing between the drawdown and disbursement of funds. Responsible Party: Krista Berry, Controller

Finding Number: 2022-004, 2021-004 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Business Manager Anticipated Completion Date: June 30, 2023 Planned Corrective Action: Business Manager will communicate with School?s financial institution to have reports generated in June instead of January.

2022-1 Excess Residual Receipts Condition: The Project did not prepare a HUD 9250 to remit excess residual receipts, nor did it mail a check or transmit a wire of those funds. Criteria: According to the Consolidated Appropriations Act, 2017, owners subject to a Section 202 or 811 Project Rental Assistance Contract (PRAC) are required to remit any excess balance in a Residual Receipts account, greater than $250 per unit, to HUD?s Accounting Center upon termination or renewal of the PRAC contract. Effect: Residual receipts balance is $598, 546 as of December 31, 2021. The allowable balance is $10,000 ($250 X 40 units), resulting in excess residual receipts. Recommendation: I recommend the Property prepare the HUD 9250 requesting to remit excess funds to HUD. Management Response: It is our understanding that the Board of Directors will be requesting a meeting with HUD to discuss the dissolution of this item. Upon meeting with HUD it will be discharged. T

Management has seen significant turnover in the Social Services Department in 2022, which included the fiscal and director positions. Staff is slowly being hired and an outside financial advisor has been hired. This advisor will work through these issues and train the new staff in proper segregation of duties and the importance of internal control review by a second employee. Management has hired a new director and new fiscal. The fiscal will be designated to prepare the grant claims and the director will review and approve the grant claims for submission.

2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District will update its existing policies and written procedures to conform to Uniform Guidance requirements. Responsible Contact Person: Dr. Rodney Asse - Assistant Superintendent for Business Riverhead Central School District 814 Harrison Avenue - Riverhead, New York, 11901 Anticipated Completion Date: The District adopted a Federal Funds Procedural Manual on January 24, 2023.

Finding 2022-002 ? Cash management ? RAD Conversion ? Replacement Reserves. CFDA 14.850 ? Noncompliance and Significant Deficiency Corrective Action Plan: Replacement Reserve deposits were made on a quarterly basis during the fiscal year for all RAD PBV Properties and were deposited into an interest-bearing account. However, the initial deposit required per the RCC was overlooked. It was immediately rectified after the discussion with the auditor, the review of the agreement and the confirmation from the bank account. The Replacement Reserves will remain current with required balance requirements through timely deposits in accordance with the RCC beginning March 2023. Responsible Staff: Kim Sampson, Finance Manager Shauna Boom, Executive Director Anticipated Completion Date: 2/14/2023

Management of Jennings Real Estate, LLC is in agreement with the finding and the auditor's recommendation to adhere to internal procedures.

RE: Lutheran Social Services of Central Ohio Marion Place II Housing, Inc. Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding Number: 2022-001 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $5,675 into residual receipts on September 23, 2022.

Finding Number: 2022-002 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $22,809 into residual receipts on September 23, 2022.