Corrective Action Plans

The City has taken appropriate measures to resolve the finding in future years.

The YWCA will separate the duties of the key functions by adding additional employees, training existing employes and utilizing non-financial personnel where applicable.

The clerk is preparing and reporting COVID-19 funds and will work with the supervisor and treasurer to ensure correct reporting in the future. To be implemented in the next reporting cycle April 2024.

• Condition: During testing of required financial reports and invoices, we noted differences in the amounts of expenses reported to grantors compared to actual expenses incurred during those periods. • Response Response MHA relies on our accounting representative to ensure that the invoices submitted to the accountant each week are added to the appropriate GL account to ensure the cost report reflects the correct amounts being reported to the grantors match the actual expenses incurred. • Planned Corrective Action: Again, monthly meetings reviewing the cost reports and GL together will reduce mistakes like this from MHA and the Accounting Rep. moving forward. MHA and the Accounting Rep will review the expenses being submitted for reimbursement together to ensure expenses incurred match the expenses being reported to the grantor.

• Condition: During our testing of reimbursement requests, we identified amounts that were requested for reimbursement prior to the expenses being incurred. • Response MHA relies on our accounting representative to ensure that the invoices submitted to the accountant each week are added to the appropriate GL account to ensure the account is being invoiced for the correct expenses during the proper timeframe. • Planned Corrective Action: During the newly established monthly meetings that will take place, MHA and the Accounting Rep will review the expenses being submitted for reimbursement together to ensure no invoices are submitted in advance.

In accordance with federal audit protocols, our organization underwent a rigorous evaluation administered by Jessica Sayles, CPA, representing the prestigious firm Houldsworth, Russo, and Co. for fiscal year 2021-2022. Specifically, the audit was conducted with a focus on our utilization of funds allocated under the ARP grant. This comprehensive audit revealed two distinct facets deserving of meticulous attention. Firstly, we are pleased to report that the examination of our direct expenditures under the ARP grant has yielded an impeccable record of financial stewardship. No anomalies, deficiencies, or discrepancies were identified in the management of these direct expenses. This outcome reaffirms our unwavering commitment to fiscal diligence in the administration of public funds. However, the audit did unveil an issue of significance, pertaining to our handling of indirect expenses and fringe rates. Ms. Jessica Sayles, discerned that our organization had inadvertently transgressed established regulations governing allowable indirect cost rates, particularly in relation to payroll and other miscellaneous expenses. This misapplication resulted in the disbursement of funds beyond the thresholds specified under the Uniform Guidance framework, consequently necessitating reimbursement to federal agencies. This disclosure is an acknowledgment of the audit findings and represents our steadfast commitment to forthrightness, transparency, and responsible financial management. We deeply respect the critical importance of precision and adherence to federal guidelines in matters of fiscal accountability, and we are dedicated to addressing these issues with utmost professionalism. Issue 1: Material Adjustments to the Financial Statements We acknowledge the discovery of material current and prior period adjustments necessary to ensure that our financial statements are fairly stated in accordance with generally accepted accounting principles (GAAP). We understand the importance of accurate financial reporting and have already taken steps to address this concern. Our response to this issue includes: Comprehensive Review: We have initiated a thorough review of our accounting records to identify the root causes of these material adjustments. This process includes examining internal controls and financial reporting procedures. Rectification Plan: A plan has been developed to rectify these adjustments promptly, with a focus on maintaining compliance with GAAP. This includes improved monitoring, internal auditing, and reporting protocols. Training and Development: Our finance and accounting team have undergone additional training and development to strengthen their understanding of financial reporting standards, and GAAP compliance. Issue 2: Uniform Guidance - Allowable Indirect Cost Rates We acknowledge the findings related to the misapplication of allowable indirect cost rates for payroll and other expenses. We deeply regret the misunderstanding that led to this issue and take full responsibility for it. To address this matter, we have initiated the following actions: Immediate Compliance: We have already taken steps to ensure that allowable indirect cost rates are correctly applied in accordance with Uniform Guidance. This includes a review of all grant expenditures and related indirect costs. Training and Education: We are committed to improving our management's understanding of allowable indirect cost rates. Specialized training sessions will be conducted to clarify the proper application of these rates to prevent such errors in the future. Reconciliation and Repayment: We have worked closely with federal agencies, who opted for a refundable advance, to reconcile the amounts overdrawn on federal requests for reimbursements and promptly addressed any amounts due as a result of the misapplication of indirect cost rates. We recognize the gravity of these findings and are actively working to ensure that such misapplications will not recur in the future. In tandem with this, we commit to working diligently alongside Ms. Sayles and her esteemed team to expeditiously rectify these concerns and establish a robust framework for accurate financial reporting in our future endeavors. This organization remains firmly committed to upholding the highest standards of integrity, accountability, and compliance in its financial operations. We extend our appreciation to your department for your dedication to ensuring responsible fiscal oversight and the judicious allocation of federal resources. Should you require additional information or wish to engage in a more detailed discussion of these matters, we are readily available for dialogue. Andrea L. Gregg Chief Executive Officer High Sierra AHEC 639 Isbell Road, Suite 290 Reno, NV 89509 (775) 507-4022 andrea@highsierraahec.org

Recommendation: The Association should ensure source documentation is maintained for all costs and elements of a cost calculation reimbursed by federal awards. Explanation or disagreement with audit finding: There is no disagreement with the audit finding from responsible officials that two out of forty wage rate authorization forms requested were not located. Other documentation was submitted that supported the wage rates, including results of a salary survey performed by an HR consulting company. Actions taken in response to finding: In response to the finding, the Association generated detailed pay rate change history reports from the payroll system for these two employees and took a random sample of pay history for three other employees. Nothing unusual was identifiable. The Association will ensure source documentation is maintained for all federal award cost reimbursements by taking the following actions: • At least two Association leadership staff members will review all payroll changes and save documentation in secure, electronic personnel files and payroll processing files. • An improved human resources information and payroll system with more robust time tracking, reporting and document storage features is being implemented. • Detailed requirements for payroll changes will be added to revised finance and human resources policies and procedures (currently under revision). Name(s) or the contact person(s) responsible for correction action: Laura Dale, Director of Finance Bob Marsalli, CEO Planned completion date for corrective action plan: January, 2024

Agree with the finding. We will implement the segregation of duties matrix as part of SOPs. We will ensure that authorization and review of cash draws of fedral funds are done by some one other than the individual who initiates and records the transaction . We have implemented the same and Dr EIli (pi) is reviewing and approving the report before each withdrawal. The Finance Head ( Nafih) is withdrawing the fund .Anticipated Completion Date : 12/31/2022 Actual date of implementation :01/24/2023

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Finding number 2022-001: CFDA 14.157 - Section 202 Capital Advance Recommendation: When the financial statements are reviewed the surplus cash computation be printed and submitted for disbursement if it shows an amount due. Action Taken: The overdue deposit will be made in 2023. In the future, audited financial statements will be reviewed upon finalization and any required deposit to residual receipts will be made in a timely manner. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Matthew Fontaine at (860) 951-9411 extension 249.

Children and Youth Programs Assistance Listing 93.090 Guardianship Assistance Assistance Listing 93.645 Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing 93.658 Foster Care Title IV-E Assistance Listing 93.659 Adoption Assistance Assistance Listing 93.778 Medical Assistance Program Assistance Listing 93.556 MaryLee Allen Promoting Safe and Stable Families Program Act 148 Pennsylvania Department of Human Services Views of the Responsible Officials and Corrective Action Plan: After a recent discussion with the [PA] Office of Children, Youth, and Families (OCYF), DHS was informed that compensation plans for FY21 and FY22 were on file and under review. However, approval was pending. OCYF explained that the State reviews plans on a calendar-year basis. However, city pay plans change during a July-June fiscal year. Therefore, the possibility of overages can occur because of salary increases or other personnel changes. The process is that once the new compensation plan is received, the reviewing authority would flag any items that are in excess of the existing approved rates. At that time, DHS would be permitted to submit a waiver for the items in question. Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.

Views of Responsible Officials: Mary's Center now has a robust process where the agreed upon provisional indirect rate or (if applicable) the specific rate included in the final Grant agreement is the governing default rate used for each Grant. In any scenarios where a change in rate is being requested, the Program Manager alerts the Senior Grant Accountant assigned to the grant and provides supporting documentation from the Grant funder of an addendum to the existing Grant agreement. If for any reason the Finance team is using an upward or downward adjustment to the provisional indirect rate or what was agreed upon in the Grant agreement the EVP Finance and Director of Grants must approve this change and notify the EVPs of Health and Programs and Development prior to implementing this change. All changes are documented. In addition, to ensure the rate in the agreement is the same rate being used when invoicing Grant funders, the Finance team conducts a thorough reconciliation process during the year.

Views of Responsible Officials and Planned Corrective Actions Management acknowledges the finding, and the management staff of the Institute take seriously the federal compliance requirements that apply to drawing funds from the DHHS Payment Management System. The Institute recognizes that it has drawn down excess funds. The Institute plans to improve policies and procedures for cash management in 2023 that will ensure the calculation for allowable cash draw for actual immediate cash needs is complete and accurate. Action Taken Scintillon plans to improve policies and procedures for cash management in 2023 that will ensure the calculation for allowable cash draw for actual immediate cash needs is complete and accurate.

Planned Corrective Action: The Planned Corrective Action is to instruct future GID Grant Managers the importance of having qualifying receipts or invoices that correspond directly to the amount of Federal funds being requested for reimbursement. To facilitate this successfully, Project costs must be paid with non-Federal entity funds before summitting a payment reimbursement request from the Grant program funds. Name of Contact Person: Erling A. Juel, District Manager, will be responsible for implementing this corrective action by working with the District’s grant managers to properly implement the corrective action for on-going and current grants. Anticipated completion date: The Corrective Action will be implemented immediately and applied to the administration of on-going Federal grants.

The Organization will deposit $15,814 of surplus cash into residual receipts as soon as possible. The anticipated completion date is December 31, 2023.

The Organization will enhance its procedures and internal controls with respect to preparation and requests of funds. Grant agreements will be reviewed to confirm if expenditures being requested are allowed. The Organization will also hire an additional grant accountant to ensure proper controls are in place.

The Organization will enhance its procedures and internal controls with respect to preparation and requests of funds. Grant agreements will be reviewed to confirm if expenditures being requested are allowed. The Organization will also hire an additional grant accountant to ensure proper controls are in place.

The Organization experienced turnover in accounting management at the end of 2020 and throughout 2021. At that time, the interim management did not have the background with the grant RFR submitted necessary to reconcile to the grant general ledger. Effective March 2022, a Director of Finance was brought onboard to develop and strengthen the financial function for AIDS Outreach Center Inc., The presence of the new Director has greatly improved the financial processes, and internal controls. However the Director of Finance, has not had adequate time to fully implement the corrective action plan as the prior audit was completed in September 2022. For YE 2023 AIDS Outreach Center Inc., will have had the time to fully implement controls over the grant RFR process to avoid the risk of noncompliance related to proper recordkeeping for reporting documentation.

The County plan has been implemented.

Finding 2022-6 - Special Tests and Provisions: In accordance with the Project's regulatory agreement with HUD, management shall establish a residual receipts account and make deposits into the account in accordance with HUD requirements (within 90 days after the close of the fiscal year). Disbursements from such fund may be made only after written consent is received from HUD. Management's View: Management acknowledges finding and simultaneously underscores this was was an internal facing situation. Proposed Corrective Action: Management will ensurethat all proper approvals from HUD are obtained before making a withdrawals from residual receipts account. Anticipated Correction Date: Payments are done automatically on a monthly basis.

FA 2022-001 Strengthen Controls over Special Reporting Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199; 225GA324N1199 Questioned Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process. Corrective Action Plans: The School District has returned to collection Free and Reduce applications and recording the student meals accordingly. Estimated Completion Date: July 1, 2022 Contact Person: Chris Johnson, CGFM, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

Findinq No.: 2022-019 Cash Management Responding Agency:Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director (DOA) The agency disagrees with this finding. Per Homeowner's Assistance Fund guidance, funds are requested from the US Treasury and remitted in advance. This is not a reimbursement program and not subject to the State Cash Management lmprovement Act as is the case for other funding advances under the American Rescue Plan Act of 2021 .

Finding Reference Number: 2022-2 Recommendation The Company must deposit $53,053 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Completion date or proposed completion date: June 2023 Action(s) taken or planned on the finding As of June 2023, management has deposited $53,053 into the residual receipts reserve.

REFERENCE # 2022-004 CASH MANAGEMENT – MATERIAL WEAKNESS- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Non-Federal Entities Other Than States- Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Questioned Costs: Cannot be determined Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Corrective Action Plan: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

REFERENCE # 2022-003 OTHER - BASIS OF ACCOUNTING – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Basis of Accounting —Uniform Guidance states the basis of accounting used may be a special purpose framework. However, it does state that the determination of when an award is expended must be based on when the activity related to the federal award occurs. Uniform Guidance also states for Grants, cost reimbursement contracts, cooperative agreements, and direct appropriation type of contracts, the federal expenditure or expense should be reported when the transaction occurs. Uniform Guidance further states, the auditee should also be able to reconcile amounts presented in the financial statements to related amounts in the schedule of expenditures of federal awards. Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division report to the pass-through entity on an accrual basis. Division’s schedule of expenditures of federal awards is presented on the accrual basis of accounting. Of the Sixty (60) files selected for testing: • Five (5) prior year expenditures were included in Division’s current year schedule of expenditures of federal awards. Questioned Costs: Cannot be determined Recommendation: We recommend Division report program expenditures in the year expenditures were accrued. Corrective Action Plan: The Division will report program expenditures in the year expenditures were accrued. Step 1 Action Date: Ongoing Final Implementation Date:h 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

We concur with the recommendation, and a formalized and independently monitored process was implemented to reconcile refundable advances routinely and in coordination with the recognition and allocation of allowable costs effective August of 2023.