Corrective Action Plans

Responsible Individual: William Bridgeman, Natalie Alvarez, George Dean Corrective Action Plan: Greater Phoenix Urban League (Delegate Agency) will collaborate with the City of Phoenix (Grantee) in evaluating the process and effectiveness of inserting and updating the ?quarterly administrative reporting package?, relatively to its use and the accuracy of the content that flows within the excel workbook. Anticipated Completion Date: On going throughout the contract period on an annualized basis. June 30, 2023

Responsible Parties: Michelle Lancaster, Deputy County Manager / Human Services Director Beverly Liles, Finance Director Finding 2022-003, Significant Deficiency and Nonmaterial Noncompliance - Special Test and Provisions See Corrective Action Plan for chart / table.

Corrective Action Plan Finding 2022-001 Audit Recommendation: Procedures should be consistently applied requiring the reconciliation of submitted personnel activity reports to the employees' actual costs allocated and charged to federal and other programs. Planned Corrective Actions: This finding was initially identified during fiscal year 2020, and corrective actions were taken by the School in 2021. To address the issue, the School implemented new procedures that require a monthly review by management, which includes a detailed reconciliation of submitted personnel activity reports to vouchers prepared for federal and other programs. This reconciliation process helps to ensure that payroll cost allocation accurately reflects the submitted personnel activity reports. In addition, the School has made changes to its payroll system to ensure accurate time tracking for its various programs. This includes changing the service provider responsible for voucher submissions. These changes will help to prevent similar issues from occurring in the future and ensure that employee-related costs are accurately allocated to the appropriate programs. As of 2022, the School has successfully implemented these changes and continues to review and monitor its procedures to maintain compliance with federal and other program regulations. Anticipated Completion Date: June 30, 2022 Contact Person: Rita Nolan, Executive Director

Corrective Action Plan Finding 2002-002 Audit Recommendation: Procedures should be implemented requiring the reconciliation of submitted reimbursement requests to the related support (such as bills, invoices, etc.) retained. Planned Corrective Actions: Management will develop written procedures outlining the steps required to reconcile submitted reimbursement requests to related support retained, such as bills, invoices, receipts, etc. The procedures will include a review and approval process to ensure compliance with federal and other program regulations. All staff members and contractors responsible for preparing and submitting reimbursement requests will receive training on the new procedures. This will include instruction on the importance of reconciling reimbursement requests to supporting documentation. Management will assign a responsible staff member to regularly monitor the reimbursement request process to ensure compliance with established procedures. This individual will be responsible for reviewing a sample of reimbursement requests each month to ensure they are accurate and properly supported. Management will regularly review and evaluate the effectiveness of the new procedures and make necessary adjustments as needed. Anticipated Completion Date: February 28, 2023 Contact Person: Rita Nolan, Executive Director

Identifying Number: 2022-009 Finding: Period of Performance: payroll costs Corrective Actions Taken or Planned: UCAN agrees with this finding and is committed to strengthening internal controls to ensure that amounts are properly recorded and reported. UCAN has already taken steps to insure that items are billed in the period incurred and only items that fall into the grant period are billed. We believe that significant turnover in the finance department led to this deficiency, so we are actively documenting procedures and cross-training employees, so we always have coverage. All vouchers will also go through a review process before they are sent to the funder. This is a repeat finding, with the original corrective action plan to be completed before June 30, 2023. We do believe that corrective actions that have been taken have resolved this issue. Contact person is Kimberly Parish, Chief Financial Officer and she can be reached at kim.parish@ucanchicago.org.

Finding 2022-001- Allowable Costs, Activities Allowed and Special Tests and Provisions Contact Person: Lori Dixon Management?s Response: GRMC management will implement the following processes/procedures as a result of the finding of the 2022 Single Audit. During the audit review, FEMA hours were found to be unallowable on sample patients treated for COVID. Management reviewed the findings and identified additional patients/hours not covered by other funding sources to replace the unallowed data totaling $8,550. Completion Date: The steps above will be completed by October 31, 2023.

U.S. Department of Health and Human Services 2022-002 Health Centers Cluster ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization develop a process to address changes in the approved IDCR midway through grant periods where grant expenditures are reconciled to the new IDCR, and additional direct expenditures identified, if needed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement processes to review the IDCR used to ensure any changes are incorporated timely and reconciled, as needed. Name(s) of the contact person(s) responsible for corrective action: Jenny Singh, Finance Officer Planned completion date for corrective action plan: December 31, 2023

Finding Number: 2022-001 Program Name/Assistance Listing Titles: Crime Victim Assistance; Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services Assistance Listing Numbers: 16.575, 93.671 Contact Person: Jessica Bryson, Finance Administrator Anticipated Completion Date: Completed effective October 2022 Planned Corrective Action: During the audited fiscal year, the organization experienced significant staff turnover in the Finance Department. As a result, the methodology of accounting relative to class/customer tracking changed part-way through the year. This resulted in the inability to immediately produce documentation from the financial reporting software that corroborated the grant billings. Although the organization is confident that expenses were billed to appropriate grants throughout the year (due to backup documentation in the grant billing portals), the organization?s financial software did not directly reflect this. To correct this problem, a new class/customer tracking system has been established to ensure that the financial reporting software more accurately tracks expenditures related to Federal Awards and organizational programs. Furthermore, grant billings are regularly reviewed by an independent accounting firm, the organizations Treasurer, and/or the Executive Director to ensure proper coding/tracking.

2022-002) Reporting Management?s response and corrective action is as follows: The Office of Community Development (OCD) was in contact with the Treasury to resolve an error with the Treasury reporting portal that prevented report submission. The error was not resolved by Treasury until June 2022. The monthly report requires reporting of the number of households that received assistance and the total amount of ERAP funds paid for those participants in the reporting period. A City-Parish contractor issues the rental assistance and requests reimbursement from the City-Parish at a later date. The Treasury reports are due prior to the reimbursement being paid to the contractor. However, costs for the participants must still be included in the Treasury Report. Due to this timing difference, the monthly report would not be supported by the City-Parish accounting records at the time of the report being filed. Expected Implementation Date: December 2023 Contact person: Marlee Pittman, Interim Director, Office of Community Development

2022-008) David Bacon Wage Requirements Management?s response and corrective action is as follows: All OCD contracts with developers include requirements to comply with Davis-Bacon. As part of the approved policies and procedures, the OCD requests evidence of Davis-Bacon compliance during the closeout of the project in order to ensure complete records. The OCD withholds the retainage at the end of the project until those records are received and reviewed as part of project close-out. The project cited for a lack of Davis-Bacon monitoring began the close-out process just as the audit was being finalized in June 2023 and per the OCD policy, the final reimbursement to the developer is being held until complete Davis Bacon records are submitted, reviewed, and approved. To implement best practices moving forward, the OCD is reviewing the policies and procedures and identifying ways to improve the collection and review of Davis-Bacon compliance. The current staff is scheduled to participate in training and is developing new reporting requirements in alignment with that training. Expected Implementation Date: July 2023 Contact person: Marlee Pittman, Interim Director, Office of Community Development

FINDING 2022-003 Subject: Child Nutrition Cluster ? Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: We noted that for one claim in a sample of four, there was no formal evidence of the sponsor claim reimbursement summary being reviewed by someone independent of who prepared the sponsor claim reimbursement summary prior to submission. Description of Corrective Action Plan: The food service director will have the treasurer, deputy treasurer, or an administrator review and sign off on the sponsor claim reimbursement summary prior to submission. Responsible Party and Timeline for Completion: Jenny Dunning, Food Service Director ? this will be implemented immediately following the audit in March 2023.

FINDING 2022-002 Information on the federal program: Subject: Child Nutrition Cluster Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program, Fresh Fruits & Vegetables Program Assistance Listing Numbers: 10.553, 10.555, 10.559, 10.582 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: We noted that for four claims in a sample of four, the meal counts were overclaimed for the month. We noted that in October 2020, the School Corporation had overclaimed lunches by 823 meals and breakfast by 512 meals, in April 2021, had overclaimed lunches by 210 meals and breakfast by 58 meals, in October 2021, had overclaimed lunches by 90 meals and breakfast by 632 meals, and in April 2022, had overclaimed breakfast by 984 meals and fresh fruits and vegetables by 114. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will verify that each claim has been reviewed by a secondary person for accuracy and that the claim agrees to underlying detail for meals served. Responsible Party and Timeline for Completion: April 01, 2023

Finding No: 2022-001 Activities Allowed or Unallowed/Allowable Costs 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 Award Year: January 1, 2020 through June 30, 2022 (a) Criteria or Requirement Per 2 CFR 200.303, the non-Federal entity 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 statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our test work, we selected a sample of 60 non-payroll disbursements made during the fiscal year 2022 reporting period. We noted seven instances in which expenditures were approved for payment based on vendor invoices which included inaccurate calculations. In an eighth instance, a moving expense that was paid during June 2020, but authorized prior to January 1, 2020 was approved for payment. In addition, the University was unable to provide evidence of management review and approval for 14 of the 60 disbursements sampled. These 14 disbursements were for allowable costs under the terms and conditions of the program. (c) Possible Cause The University has a management review process to review invoices and related documentation before payments are disbursed. The University management review control that was in place did not operate effectively to prevent unallowable charges and inaccurate amounts from being submitted for reimbursement by the federal agency. In addition, the University was unable to provide evidence of certain management reviews and approvals due to employee turnover subsequent to the time that the underlying activity occurred. (d) Questioned Cost None reportable. (e) 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. (f) Statistical Validity 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 University strengthen controls over the management review process to prevent unallowable costs and inaccurate amounts from being charged to Federal programs and to enhance the retention of evidence of management review and approval. (i) View of Responsible Officials Management concurs with the finding. While appropriate controls exist relative to management review and recalculation of expenditures, opportunity exists to retrain staff and further enhance controls. (j) Corrective Action Plan Management will ensure communication of the finding with its Accounts Payable Department and provide appropriate retraining for all levels of staff. Training will emphasize allowable versus unallowable expenditures, recalculation of expenditure amounts, and documentation of management review/approval. The moving expense in question will be removed and we are not charging any moving expenses to the PRF going forward. Management approvals are now uploaded along with the documentation into our general ledger so that if employee turnover occurs, we are still able to see the documentation of review. (k) Anticipated Completion Date Completion of corrective action anticipated by December 1, 2022. (l) Name of Contact Person for Corrective Action Brian Courtney, Assistant Chief Financial Officer: (251) 405-9969

Finding No: 2022-003 Activities Allowed or Unallowed/Allowable Costs Federal Agency: U.S. Department of Transportation Assistance Listing Number: 20.205 Pass-through Entity: Alabama Department of Transportation Pass-through Award Number: #2283(OX-002283-000) Program: Highway Planning and Construction Cluster Award Year: August 4, 2021 through January 13, 2024 (a) Criteria or Requirement Per 2 CFR 200.303, the non-Federal entity 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 statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our test work over the Highway Planning and Construction program, we selected a sample of 50 disbursements made during the fiscal year. For one of the 50 disbursements sampled, we noted that the expenditure was approved for payment based on an inaccurate calculation on the underlying vendor invoice. (c) Possible Cause The University has a management review process to review invoices and related documentation before payments are disbursed. The management review control that was in place did not operate effectively to prevent inaccurate amounts from being submitted for reimbursement by the federal agency. (d) Questioned Cost None reportable. (e) Effect Federal funds were expended for inaccurate amounts. (f) Statistical Validity 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 University strengthen controls over the management review process to prevent inaccurate amounts from being charged to the Federal programs. (i) View of Responsible Officials Management concurs with the finding. While we have an adequate process in place, those responsible for steps of the review process need to be reminded of the importance of completing adequate reviews. (j) Corrective Action Plan An email will be sent to the Research Operations Council that reminds administrators, who are responsible for processing invoices, to confirm invoice calculations prior to processing for payment. Research administrators will also be re-trained at the next Research Operations Council meeting on the importance of thoroughly reviewing invoices received for payment. Inaccurate expenditures will be removed. (k) Anticipated Completion Date Email reminder of proper invoice review protocol sent November 11, 2022. Inaccurate expenditures will be removed from project by December 1, 2022. In-person reminder of process will be discussed at next in-person ROC meeting which is currently scheduled for December 1, 2022. (l) Name of Contact Person for Corrective Action Lindsey Sheffield, Manager, Office of Contracts and Grants: 251-460-6052

Finding No: 2022-002 Activities Allowed or Unallowed/Allowable Costs Federal Agency: U.S. Department of Agriculture Assistance Listing Number: 10.652 Program: Research and Development Cluster ? Forestry Research Award Year: July 31, 2017 through July 30, 2022 (a) Criteria or Requirement Per 2 CFR 200.303, the non-Federal entity 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 statutes, regulations, and the terms and conditions of the Federal award. (b) Condition Found, Including Perspective During our test work over the Research and Development cluster, we selected a sample of 50 disbursements made during the fiscal year. Within our sample, we noted one instance in which certain documented costs were approved and disbursements were made for an unallowable amount due to an inaccurate calculation on the underlying invoice. (c) Possible Cause The University has a management review process to review invoices and related documentation before payments are disbursed. The University management review control that was in place did not operate effectively to prevent unallowable charges from being submitted for reimbursement by the Federal agency. (d) Questioned Cost None reportable. (e) Effect Federal funds were expended for inaccurate amounts. (f) Statistical Validity 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 University strengthen controls over the management review process to prevent inaccurate amounts from being charged to Federal programs. (i) View of Responsible Officials Management concurs with the finding. While we have an adequate process in place, those responsible for steps of the review process need to be reminded of the importance of completing adequate reviews. (j) Corrective Action Plan An email will be sent to the Research Operations Council that reminds administrators, who are responsible for processing invoices, to confirm invoice calculations prior to processing for payment. Research administrators will also be re-trained at the next Research Operations Council meeting on the importance of thoroughly reviewing invoices received for payment. Inaccurate expenditures will be removed from project. (k) Anticipated Completion Date Email reminder of proper invoice review protocol sent November 11, 2022. Inaccurate expenditure will be removed from project by December 1, 2022. In-person reminder of process will be discussed at next in-person ROC meeting which is currently scheduled for December 1, 2022. (l) Name of Contact Person for Corrective Action Lindsey Sheffield, Manager, Office of Contracts and Grants: 251-460-6052.

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to submit to HUD. Completion Date: August 3, 2022

City of Dothan Corrective Action Plan RE: FEDERAL FINDINGS AND QUESTIONED COSTS Finding 2022-001 U.S. DEPARTMENT OF AGRICULTURE: Passed Through State Department of Education: Children At Risk Feeding Child and Adult Care Program Assistance Listing Number: 10.558 Pass-Through Grantor?s Number: AKZ-0000 While internal controls are designed to provide reasonable assurance that operations are effective and reliable, there are certain areas that require further review. It was determined that inconsistencies existed in records that were required for proper grant administration. Due to inadequate supervision of the program, inconsistent and insufficient records were used in the reimbursement filing process. The City of Dothan has implemented procedures to avoid any future issues or discrepancies with expenses and reporting for the program. The Finance Department will review any monthly reports and corresponding general ledger account numbers for accuracy and consistency with the amounts provided in the monthly filings prior to submission to the Department of Education. The new program manager has reviewed all grant requirements and relevant forms required for proper grant administration. Training has also been provided to the City?s staff tasked with administering the program moving forward.

The District will evaluate all aspects and needs of the food service program including personnel, equipment such as stoves, freezers, etc. and determine the best and legally proper use of the excess funds.

Finding 2022-013 ? Internal Controls Over Grant Management (Significant Deficiency) Information on the Federal Program: U.S. Department of Education, CFDA No. 84.425, COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund Criteria: 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations and the terms and conditions of the federal awards. Condition: During audit procedures we tested controls over applicable compliance requirements. We tested two drawdowns for cash management requirements. One of the draws was a reimbursement for lost revenue. Although the method to calculate lost revenue was reviewed and approved, the individual calculations and amounts to be drawn were not reviewed and approved. We tested five disbursements made directly to students as grant awards. Of these five, four disbursements did not have documentation of review or approval of the amounts to be paid. Management?s View: Management had previously held many discussions regarding drawdown calculations and student disbursements either verbally or during in-person meetings that were not formally documented. Corrective Action Plan: Management is in process of updating Policies and Procedures. Management will ensure that all drawdown calculations will be sent to the Director of Accounting and Finance and the VP of Administration and Operations for review and approval via email. Student disbursement information, including the method of determining qualifying students and amounts, will be sent by the Dean of Students to the VP of Administration and Operations for review and approval. In the event such information is discussed verbally or at in-person meetings, documentation of date, time, and summary of the discussion will be documented. This will take effect immediately as the policies are formally updated. Anticipated Completion Date: September 30, 2023

Finding 2022-001 - Controls Over Cash Management (Significant Deficiency) Criteria: According to Title 2 U.S. Code of Federal Regulations (" CFR") Part 200 , paragraph 305, non-federal entities are required to minimize the time that elapses between the transfer of funds from the federal funding source and the disbursement of those funds by the non-federal entity for the program's intended purposes. Condition and Context: As a part of our testing over cash management of funds received from the federal funding source, we examined information showing the dates on which five program-related disbursement of federal funds were received by the Corporation , and we compared those dates to the dates when the Corporation remitted the amounts for the purposes of covering payroll expenses and paying its various contractors. We noted one draw for $1,184,367 that was received from the federal funding source with no payments made to the contractors for which the funds had been appropriated. This resulted in a period of 16 days between receipt of the federal funds and the corresponding payments to the contractors. We also noted one of the five draws tested were for an incorrect amount. The Corporation submitted a draw for $29,997 in error. The overdrawn funds were repaid to the federal funding source. The Corporation prepared a schedule of draws made during 2022 and it was noted that the Corporation drew or repaid an incorrect amount in four months of the year, of which some were corrected in the next period. Effect: As a result of these matters , the Corporation essentially borrowed money from the federal government and potentially delayed payment to vendors. Cause: The condition was caused by an oversight by management that resulted in invoices not being processed for payment unt i l well after the cash had been drawn by the Corporation and resulted in draws to processed for an incorrect amount. Questioned Costs: From our sample tests , the Corporation overdrew $29,997 for the month of May 2022. Recommendation : We recommend that management designate a specific individual to be responsible for monitoring the receipt of federal funds on a daily basis . This person should be tasked with ensuring that funds that have been transferred from the federal funding source are disbursed to the intended contractors within a short period following receipt of these funds and ensuring that the correct draw amounts are submitted. We also in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Differences were noted when comparing the summary to timecards. Within the sample of 45, we noted that 31 timecards did not have a documented review. From the sample, we noted that the pay advice form, which reflects pay rate changes, for 2 employees did not indicate signature by an approver and only indicated the requestor's signature. The employees' new pay rate as indicated on the pay advice form was reflected in the payroll expenditure. Additionally, within the sample of 45, we noted 1 employee that did not have a pay advice form or contract to support the pay rate. We noted the following control items: ? 31 out of 45 timecards tested did not have documented review. ? 2 out of 45 employees tested did not have pay advice forms signed by both the requestor and reviewer. Only the requestor signed the form. ? 1 out of 45 employees tested did not have a pay advice form or other supporting documentation for the pay rate. Effect: Payroll expenditures could be inaccurately charged to the federal grant. Cause: The lack of documented timecard and pay rate approval were an oversight. Questioned Costs: None Recommendation: We recommend the Corporation maintain documented approval of all timecards and pay rate increases. Views of Responsible Officials and Planned Corrective Actions: The Transportation Department provides a spreadsheet that details time operators work by route. This process is used to align FTA funding streams with routes driven. The spreadsheet is kept by the Transportation Manager and reviewed by the Director of Transportation. These two positions approve time prior to submitting it for processing. GPTC is engaging its current payroll provider to assist in finding a technological solution to capturing start and end times of each operator. Until we can get this technical solution, an approval form will be submitted by the Transportation Department along with the allocation spreadsheet. As stated above, GPTC experienced a lot of turnover and personnel changes - the Human Resource Department had many. Pay advices are managed by this department. Our recommend that management prepare a schedule of all claims to determine whether there are additional amounts that have been overclaimed. Views of Responsible Officials and Planned Corrective Actions: In 2022, GPTC experienced a lot of turnover and personnel changes in multiple areas. In reassigning responsibilities, the Finance Department was designated as the area to handle FTA fund requests in June 2023. Absorption of these responsibilities required them to get an understanding of the process, formulate procedures for drawdowns, and develop a method for monitoring these dollars. The first drawdowns by the new team occurred in August 2023. FTA dollars are a major source of funding, so managing this process is highly important. GPTC has implemented a review process, as required by the FTA; and developed a spreadsheet for formulating amounts to be drawn. Iniquities in the spreadsheet were remedied in September 2023, and future processing has been good. GPTC realizes that FTA grants are reimbursable. The process requires prepayment of expenses, proof of payment, and reclamation of the FTA's portion of expended funds. So, future funds will be disbursed in a timely fashion. Large dollar amounts that require FTA funding for payment will be disbursed within three days, as required.

2022-002: Internal Control Over Financial Reporting and Compliance with Allowable Costs and Cash Management U.S. Department of Health and Human Services, pass-through State of Tennessee Department of Health - Immunization Cooperative Agreements (ALN COVID-93.268) Management?s Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the Project Manager have created a tracking document to closely monitor the assessment completed and accounted for within the requested reimbursement. The Controller will review the assessment tracker to account for only those completed assessments in 2022-year end financials. Remaining assessments will be accounted for 2023 financials. Anticipated Completion Date: With new accounting software being implemented on October 1, 2023, the correction to this accounting of assessments will be correctly attributed by November 1, 2023.

See corrective action plan

See corrective action plan

1347 Morris Avenue Corporation 290 Lenox, 3rd Floor New York, NY 10027 AUDITEE?S CORRECTIVE ACTION PLAN Name and Number of Project 1347 Morris Avenue Corporation, FHA Project Number 012-HD086 Auditor/Audit Firm PKF O?Connor Davies LLP Audit Period June 30, 2022 Finding 2022-001 ? Timely Deposit of Surplus Cash A. Comments on Finding and Recommendations Recommendation ? We recommend that management ensures the surplus cash deposit is done timely in the future. B. Actions Taken or Planned Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Going forward our focus will be to work with the auditor and owner to get the audits finalized earlier so adequate time is left for the deposits to be made. In instances where the final is not going to be issued and allow enough time, the deposit will be made based on the reviewed draft. C. Status of Corrective Action on Prior Findings No prior findings. Ezra Mill, CFO

Program: Low Rent Public Housing AL Number: 14.850 Finding Number: 2022-001 Audit Finding (Copied & Pasted Directly from Auditor?s Report): Condition: During our audit, the Authority transferred PHA cash and charged asset management fees in AMP 2 and AMP 3 in excess of the excess cash amount from the 2021 audited numbers. Context: AMP 4 and AMP 10 have issues cash flowing and rely on the other AMPS to transfer excess cash every year. In 2021, the other AMPs had less excess cash, so were unable to subsidize AMP 4 and AMP 10 like normal. The Authority did not detect the cash flow issue until after the fiscal year ended. Resulting in noncompliance with the program's rules Cause: Controls were not followed to ensure fungibility rules between each project were followed Criteria: After subsidy (operating) is calculated at a project level, operating subsidy can be transferred as the PHA determines during the PHA's fiscal year to another ACC project(s) if a project's financial information, as described more fully in 240 CFR ? 990.280, produces excess cash flow, and only in the amount up to those excess cash flows. 240 CFR ? 990.205. Corrective Action to Be Taken: Executive Director, Holly Girdwood, is responsible to train/teach the Comptroller, Tara Sheffler, to perform monthly reconciliations to ensure fungibility is properly maintained. This should be completed prior to year-end December 31, 2023. In response to the context, it was our understanding that we could charge asset management fees to all AMPS due to COVID guidelines. Contact Responsible for Corrective Action: Tara Sheffler Comptroller PO Box 988 481 Neshannock Avenue New Castle, PA 16103 724-656-5100 ext. 5100 tsheffler@lawrencecountyha.com