Corrective Action Plans

Tompkins cortland community college will pass a resolution this summer requiring the comptroller's Department to reconcile monthly all accounts restricted and unrestricted in the college. ln turn the Comptroller and eventualty the vice president of Finance will be responsible to verify that the Ledger and subsidiary Ledgers are correct and fairly state the accurate financial picture of the College. The assistant comptroller will be reconciling all the college operating, capital and restricted accounts. There will be a process giving them until the 15h of every month to reconcile to the college's General Ledger. The comptroller will be signing off at all the reconciliations and relevant entries ensuring accuracy and completenessof the accounting records for the college and between component units. The principal account clerk will be reconciling all the restricted and unrestricted accounts for the Foundation and the FSA. The employee will have until the 15th of every month to reconcile all the accounts including all the Foundaiion and FSA general Ledgers. The comptroller will review and sign off on all the reconciliations and relevant journal entries ensuring accuracy and completeness of the accounting records for the Foundation, FSA and between component units. component units.

Planned Corrective Action: Monthly bank reconciliations and journal entries are completed by staff accountants and reviewed by the Chief Financial Officer. Historically, this process has not been documented as files are retained electronically and our accounting software, Resman, does not offer the functionality of in-system approvals. In 2025, we will implement a control to document this review process. Planned Implementation Date of Corrective Actions: Fiscal year ending 12/31/25

Planned Corrective Action: Monthly bank reconciliations and journal entries are completed by staff accountants and reviewed by the Chief Financial Officer. Historically, this process has not been documented as files are retained electronically and our accounting software, Resman, does not offer the functionality of in‐system approvals. In 2025, we will implement a control to document this review process. Planned Implementation Date of Corrective Action: Fiscal year ending 2025, we will implement a control to document this review process. Person Responsible for Corrective Action: Chief Financial Officer

Planned Corrective Action: Monthly bank reconciliations and journal entries are completed by staff accountants and reviewed by the Chief Financial Officer. Historically, this process has not been documented as files are retained electronically and our accounting software, Resman, does not offer the functionality of in-system approvals. In 2025, we will implement a control to document this review process. Planned Implementation Date of Corrective Action: Fiscal year ending 2025, we will implement a control to document this review process. Person Responsible for Corrective Action: Chief Financial Officer

Planned Corrective Action: Monthly bank reconciliations and journal entries are completed by staff accountants and reviewed by the Chief Financial Officer. Historically, this process has not been documented as files are retained electronically and our accounting software, Resman, does not offer the functionality of in-system approvals. In 2025, we will implement a control to document this review process. Planned Implementation Date of Corrective Action: Fiscal year ending 2025, we will implement a control to document this review process. Person Responsible for Corrective Action: Chief Financial Officer

Planned Corrective Action: Monthly bank reconciliations and journal entries are completed by staff accountants and reviewed by the Chief Financial Officer. Historically, this process has not been documented as files are retained electronically and our accounting software, Resman, does not offer the functionality of in-system approvals. In 2025, we will implement a control to document this review process. Planned Implementation Date of Corrective Action: Fiscal year ending 2025, we will implement a control to document this review process.

2024-001 Reporting (Financial) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460, (9/1/2023-8/31/2024) Finding Type: Material Weakness and Noncompliance Responsible personnel: Alyssa Timko, Director of Financial Aid, act2156@tc.columbia.edu, 212 678-3654 Corrective Action Plan: In September 2023, the College identified a technical issue with the manual reporting process for student loan disbursements to COD and determined the existing solution was only partially functioning at that time. While some loan activity was timely and properly reported to COD, other student disbursement transactions were stalled and reported after the 15-calendar day requirement. At that time, the College’s ERP, Banner, job submission process for disbursement reporting to COD was manually initiated by the Office of Financial Aid. The resulting reports were then uploaded through the DOE’s EDconnect, a Windows based software application, using WinSCP file transfer (the same process was used for return files from COD). After an evaluation, it was determined that a new solution and process was required to ensure proper, complete and timely reporting under the regulations. The reporting process was redesigned in October 2023 as part of a plan to automate loan origination and now functions through Automic, a workload automation software. Instead of manually generated files and upload / receipt through EDconnect, student loan disbursement records are now automated to/from COD using TDClient, which is a command software for sending and receiving student aid related information through the DOE’s Student Aid Internet Gateway (SAIG). The new process regularly transfers loan disbursement data to COD. However, the College also determined that a prescheduled pause in the Automic loan origination process at the end of the fiscal year 2024 academic year (in August 2024), which was established in accordance with the regulations, also inadvertently paused loan disbursement reporting and resulted in late submissions. The Office of Financial Aid has also remedied this issue by adding non-standard reporting days to the standard calendar. Along with more frequent and recurring reconciliations of Banner to COD loan disbursement data and ensuring the continuation of disbursement reporting after loan originations are paused at the end the academic year, the College does not anticipate any further late reporting matters and expects all future disbursement data to be reported within 15 calendar days.

2024-002 – Indirect Costs Auditor Description of Condition and Effect. During our testing of indirect cost rates we observed that overhead was included in the Institute's indirect cost rate reimbursement calculation for one out of the Institute's three indirect cost calculations (the general and administrative calculation). As a result of this condition, the Institute did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Institute review its policies and procedures in regard to the review of the calculation of indirect costs reimbursement to ensure that it conforms with the approved indirect cost rate and all provisions of the indirect cost rate approved by the Institute's cognizant agency. Corrective Action. Altarum’s indirect rate agreement with the Federal government is a provisional rate agreement, meaning the rates and their bases are not yet finalized. Under FAR Subpart 42.7, Altarum has the flexibility to propose the rates, and their bases provided we comply with the FAR. The following FAR clauses address flexibility:  Indirect Cost Rates: Under FAR 42.703-1, companies must accumulate indirect costs in logical groupings and allocate them using a base that reflects the benefits accruing to cost objectives. This ensures fairness and consistency in cost allocation.  Flexibility: FAR Subpart 42.7 provides flexibility in cost allocation methods, particularly under FAR 42.705 (Final Indirect Cost Rates). This section allows companies to adjust indirect cost allocation methods in response to significant changes in business operations or other relevant circumstances.  Certification: The requirement for contractors to certify their indirect cost proposals is detailed in FAR 42.703-2 (Certificate of Indirect Costs). This ensures compliance with applicable regulations and establishes the validity of the cost proposals. In June 2024, Altarum submitted a certified indirect rate proposal utilizing the total cost input method, excluding subrecipients over $25,000, as the base for our general and administrative (G&A) cost pool. This base was chosen to reflect the benefits accruing to those cost objectives. The accompanying proposed rate Altarum submitted reflected this calculation. Our provisional G&A rate was approved at the percentage that included overhead in our G&A base. However, the narrative in our provisional nonprofit rate agreement did not accurately reflect our proposal, as it inadvertently included the term "total direct costs" when describing the base for the G&A rate. For the fiscal year 2024, Altarum incorporated overhead costs into the base of the associated general and administrative cost rate as certified in our proposal to the Federal government in June 2024. To address the discrepancy between the provisional rate agreement, our proposal, and our system, we sought guidance from our cognizant agent at US Department of Health and Human Services (HHS). In discussions, Altarum was advised to update the allocation base as part of our next proposal package submission, June 2025. Additionally, we were advised that the reviewer from HHS will update the allocation base when finalizing the indirect cost rates for fiscal year 2024. Altarum will follow the advice of HHS and resolve the discrepancies in the rate agreement later this year. Responsible Person. Denise Sturm Anticipated Completion Date. 6/30/2025 – submissions to Federal government; final resolution subject to DHHS's review of our submissions.

2024-001 Other Matter – Financial assistance listing number 93.912 – HRSA ACORP – Cash management Name of contact person: Christy Daggett Corrective Action: The Organization will ensure that future grant draws through the payment management system are performed accurately. Additional training will be provided to staff to deter errors from occurring in the future. Proposed implementation date: The corrective action plan will be implemented immediately.

Global Community Charter School recognizes the management deficiencies cited by MMB+CO as finding 2024-001 in the FY2024 Audited Financial Statements. The following procedures have been implemented to mitigate and/or eliminate further process deficiencies. ● Beginning in August 2024, all participating operations staff were retrained and given clarity on the importance of accurate and timely count management. ● At the elementary and middle school, one operations person has been designated as responsible for the monthly count. This individual coordinates all personnel involved in the process and is further responsible for ensuring coverage and accuracy when personnel are shifted around or absent. ● This designated individual also meets with the food preparer weekly to check the provider’s meal count against the school's. ● The designated individual also annotates the weekly/monthly count on a digital worksheet that compares the food providers' count against the schools. ● The Director of Finance audits the worksheet monthly for “reasonability”, accuracy, and consistency. ● Post-audit, the CFO does a final review. If anything anomalous or inconsistent is found, the team will meet to confirm if the changes reflect actual student utilization. If no changes are required, the CFO takes the monthly data and uploads it to the template provided by the NSLP consultant who submits the voucher. In addition to the process outlined above, an ongoing review of student utilization is being conducted to reduce the waste and cost to the school created when too many meals are produced and students do not consume them. This process should allow meals produced to mirror consumption going forward. We implemented this process in mid-August and expect positive realignment and consistency from November 2024 onward.

During the fiscal year June 30, 2025, a process for drawing down federal funds was established. Veronica Koller, CFO requests approval for drawdown of the funds from either the COO, Magdalena Nichols or Controller, Hannah Pawlowski. Once approval is provided, the CFO draws down the federal funds.

The City of Tallahassee is committed to ensuring compliance with all grant requirements associated with the awards received from both Federal and State of Florida partners. The City was awarded $15 million from the Federal Transit Authority and $1 million from the State of Florida for the construction of the Southside Transit Center (STC). An additional $4 million was included from local sources. The issue noted came to light when the State directed City staff to request reimbursement at 5% of total costs rather than the original method of direct charging certain costs. As a result, the allocations across funding sources were updated to reflect this change in methodology. City staff immediately began the recalculation of expenditures and future budget allocations tasks and is in the process of adjusting the grant project accounting. The 3/31/25 quarterly performance and financial reports will reflect the adjustments. The next draw down of funds will include adjustments for the over reimbursement that occurred as of 9/30/24. We anticipate this process to completed by 5/30/25. Finally, the Grants Management Division has added steps to its business process to ensure compliance with match requirements and staff have begun implementation of the new process.

During fiscal year 2024, the College had two grant awards with Natural Resources Conservation Services (NRCS). The first grant award was from September 1, 2022 through August 31, 2023. The second grant award was from the date of final contract signature which was September 29, 2023 through September 21, 2028. Due to the gap period between contracts, the September 2023 NRCS general ledger was cleared of any expenses. A grant program staff member attended a training in August 2023 and submitted for travel reimbursement in October 2023. Grant program staff members attended a conference in September 2023 and the registration fees were paid in October 2023. The travel reimbursement, conference registration fees and corresponding indirect costs were included in the October 2023 financial report submitted to NRCS for reimbursement. Once the error was discovered, the expenses were removed from the NRCS general ledger and charged to an ·appro pri at e account. An adjustment was made to reduce the expenses on the October 2024 financial report submitted to NRCS. The college recognizes the importance of proper reporting for financial reports and reimbursement requests and that those reports should only include costs that are incurred during the grant period. The grant finance team will work with grant program staff to implement a schedule that will help to ensure that goods, services and travel are completed during the grant term, that invoices are submitted in a timely manner and prior to grant end, and when possible, payment will be made for said items prior to the end of the grant term. The grant finance team will review expenses incurred during the grant term and immediately following the grant term to confirm expenses are being reported in the correct period for financial reporting and reimbursement requests. Person(s) Responsible: Carrie Patton, Jen Evans Timing for Implementation: Immediate

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – TITLE i GRANTS TO LOCAL EDUCATION AGENCIES FUNDS (FEDERAL ALN 84.010) 2024-005 Internal Control Over Compliance With Federal Reimbursement Submission Deadline Requirements Finding Summary 2 CFR § 200.328 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program reporting, including reimbursement submission requirements applicable to Title I grants. During our audit, we noted the Academy did not have sufficient controls within its Title I federal program to ensure compliance with federal reporting requirements. Corrective Action Plan Actions Planned – The Academy is in the process of reviewing and updating its policies and procedures relating to reimbursement submission for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to ensure that academy personnel are following the requirements of the Uniform Guidance related to reimbursement submission requirements. Official Responsible – The Academy's Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The School’s Executive Director, Farhiya Einte, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with reimbursement submission requirements.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (FEDERAL ALN 10.553 AND 10.555) 2024-004 Internal Control Over Compliance With Federal Reimbursement Submission Deadline Requirements Finding Summary 7 CFR § 210.8 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal programs, including reimbursement submission requirements applicable to the child nutrition federal program. During our audit, we noted the Academy did not have sufficient controls in place within its child nutrition cluster federal program to ensure compliance with federal submission requirements related to claims for reimbursement. Corrective Action Plan Actions Planned – The Academy is in the process of reviewing and updating its policies and procedures relating to reimbursement submission for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to ensure that Academy personnel are following the requirements of the Uniform Guidance related to reimbursement submission requirements. Official Responsible – The Academy's Executive Director, Farhiya Einte. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The Academy agrees with this finding. Plan to Monitor – The Academy’s Executive Director, Farhiya Einte, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with reimbursement submission requirements.

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

Corrective Action: Contact Name of Responsible Person: Usha Jayanthi. The school staff involved were given training to keep proper record keeping procedures and submission of reimbursable meal counts. We have made the following employees responsible for keeping records stored for the next three (3) years. a. Jim Kim-Food service manager-Keep track of the production records; b. Stephanie Foo-Aftercare Supervisor-Keep track of the actual snack count of riembursable snack count; c. Usha Jayanthi-CFO-verify the snack count and submits reimbursement reports. Proposed Completion Date-Correction action was completed on January 15, 2024.

Corrective Action: Contact Name of Responsible Person: Usha Jayanthi. The school staff involved were given training to keep proper record keeping procedures and submission of reimbursable meal counts. We have made the following employees responsible for keeping records stored for the next three (3) years. a. Jim Kim-Food service manager-Keep track of the production records; b. Stephanie Foo-Aftercare Supervisor-Keep track of the actual snack count of riembursable snack count; c. Usha Jayanthi-CFO-verify the snack count and submits reimbursement reports. Proposed Completion Date-Correction action was completed on January 15, 2024

In response to this finding, the Culinary Services department under the guidance of the Operations team in SPS has made the following adjustments and changes to business practices: 1. The PLE tool has been formally integrated into the annual budgeting process to ensure routine compliance with this guidance and accurate financial planning. 2. If a price increase is deemed necessary, it will undergo a thorough review and approval through the SPS board governance process. This will include a landscape review of meal prices in other districts in the Puget Sound region as well as similarly scaled districts nationally. This structured approach guarantees alignment with strategic objectives while maintaining transparency and accountability. 3. As of May 2025, the Culinary Services department under the direction of the Operations department will be taking action on a price increase for school lunches beginning for the 2025-26 school year with annual reviews scheduled for subsequent years.

CONTACT PERSON For finding resolution and Single Audit matters, please contact Stacey Layman, Director of Accounting, Contracts, and Human Resources. 2024-004 INTERNAL CONTROLS OVER COMPLIANCE (11.469 CONGRESSIONALLY IDENTIFIED AWARDS AND PROJECTS) Corrective Action- All invoices are reviewed and approved by the program manager before being submitted for payment. Quarterly and semi-annual reporting are reviewed by program manager(s) prior to being submitted.

Noncompliance with Period of Performance (Public Housing Capital Fund ALN 14.872) Housing Authority staff has attended training regarding the proper reporting of CFP obligations and expenditures. The Authority’s staff will continue to attend trainings to ensure that the Authority is in compliance with all CFP reporting requirements. Date of completion: Ongoing

U.S Department of Treasury 2024-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommended that the organization implement a review and approval process for all quarterly progress report submissions. This should include: •Training staff on the importance of the review and approval process. •Ensuring adequate staffing levels to handle the review process. •Developing clear guidelines and procedures for the review and approvalprocess. •Regularly monitoring and auditing the review process to ensure compliance. Explanation of disagreement with audit finding: Management concurs with the finding. Action taken in response to finding: Additional fiscal staff has been hired to assist with various fiscal tasks including grant compliance and reporting. The guidelines are being updated, the checklist expanded, and documentation of secondary approval of reports is being retained. Grant guidelines, procedures, and checklists will be utilized to ensure compliance is maintained. Name(s) of the contact person(s) responsible for corrective action: Pete Winton Planned completion date for corrective action plan: The above action plan will be implemented in fiscal year 2025.

Condition: During audit fieldwork, our testing resulted in a restatement of fund balance in order to correct payroll liabilities that were improperly recorded in prior years. Plan: The Council and Director of Finance will implement internal controls to properly record payroll liabilities on a timely basis prior to audit fieldwork. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Kayla Gipson, Director of Finance Management Response: Agree with the finding. In FY24, we implemented a new accounting software. The Director of Finance will implement additional internal controls to ensure payroll liabilities are recorded properly.

Corrective Action Plan Emory University Office of Financial Aid Prepared by John Leach, Assoc Ve Prov/Dir, Univ Fin Aid, Office of Financial Aid Federal Program: Federal Direct Student Loans (ALN 84.268} CFR 200.303/685.300(b)(S0) Federal Award Year: September 1, 2023 to August 31, 2024 Federal Agency: U.S. Department of Education Finding 2024-001: Cash Management The reconciliation between ED's records (School Account Statements) and the school's financial and business records were prepared timely throughout the year; however, the differences identified in the reconciliation were not accounted for and no review or segregation of duties was documented as part of that process. Management Response and Corrective Action Plan: The finding was primarily caused by an unforeseen staff shortage. This led to one person being the preparer and reviewer with no segregation of duties. Although the differences were identified, they were not documented on the reconciliation form. To resolve this finding, the Office of Financial Aid {OFA) has hired new employees and implemented a new process. The Financial Operations Team is now fully staffed with two senior accountants and one senior director. As part of our ongoing efforts to strengthen internal controls and ensure the integrity of our processes, we have implemented a segregation of duties framework. This approach will help us clearly define roles and responsibilities, ensuring that critical tasks are divided among different individuals. By doing so, we will meet compliance requirements, reduce errors, and promote accountability within our office. One senior accountant will prepare the monthly reconciliation by the 10th of the following month. The senior director will review the monthly reconciliation by the 15th of the following month. In the absence of the initial preparer/reviewer, the executive director of OFA will take on the reviewer role. We understand that proper documentation is crucial for clarity, tracking, and future troubleshooting. The differences/discrepancies that are identified in the reconciliation process will be accounted for through proper documentation on the reconciliation form, which will be reviewed/investigated by a second reviewer. The Financial Operations Team within the OFA will continue to create timely and accurate monthly Federal Direct Student Loan reconciliations that compare OPUS (Emory), General Ledger (Emory), Student Account Statement-SAS (U.S. Department of Education), and GS (U.S. Department of Education). Anticipated Completion Date The corrective action plan was implemented for FY 24-25 (September 1, 2024). Responsible Department: Office of Financial Aid John B. Leach, Associate Vice Provost for Enrollment and University Financial Aid Suite 300 Boisfeuillet Jones Center 200 Dowman Drive Atlanta, Georgia 30322

Finding 2024-001 Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: In conjunction with the Town Administrator and Accountant, the Select Board will establish a written policy based on Uniform Guidance regarding cash management, determination of allowable costs, employee travel, procurement and subrecipient monitoring pertaining to federal awards. Anticipated Completion Date: December 31, 2025 Contact: Holly Young, Interim Town Administrator