Corrective Action Plans

Finding #SA2024-001 Cash Management and Accuracy of Federal Financial Reports Assistance Listing Number: 20.507 Assistance Listing Title: COVID-19 – Federal Transit Formula Grants Name of Federal Agency: Department of Transportation Federal Award Identification Number: CA-2022-083-00 • Name(s) of the contact person: Melissa Munoz, Interim Assistant Finance Director • Corrective Action Plan: Staff recognize that drawdown requests have not been submitted timely and/or accurately in the past. Critical positions that were vacant within the department have been filled, which has helped alleviate some of these issues. Current staff understands the importance of accurate and timely drawdown requests. The City is in the development phase of the grant policy and is actively working with a consultant on the policy. This policy will be partially implemented in Fiscal Year 2026. Additionally, staff will be attending a Grant Management training in Fiscal Year 2026. • Anticipated Completion Date: 06/30/2026

Cause of Finding: The Organization failed to submit a required, semi-annual grant report. This created a potential for non-compliance with federal reward terms. Action: The Executive Director and the Bookkeeper will work to ensure increased accuracy and timeliness, in providing grant reporting. The Executive Director and Bookkeeper, will both provide staff training and support to ensure they have the necessary knowledge and skill to effectively perform job functions with regards to reporting. The Executive Director has implemented and updated Internal Controls, in order to ensure proper processes are in place with regards to grant reporting. In addition, a Grant Reporting calendar has been implemented for all staff involved, as well as, an internal tracking system for grants, grant deadlines and reporting timelines. The Bookkeeper has implemented monthly check-ins with grant needs via the tracking too. Both, the Executive Director and the Bookkeeper, agree to confirm the proper timing of grant reports via the calendar and tracking tool. Anticipated Date of Completion: Completed. Completed Responsible Party: Executive Director and Bookkeeper

Cause of Finding: The Organization submitted reimbursement requests for expenses supported by invoices dated after the reimbursement date. The Organization misunderstood the timing requirements for reimbursement. Action: The Executive Director and the Bookkeeper will work to ensure increased accuracy in processing payments and reconciling the financial statements. The Executive Director and Bookkeeper, will both provide staff training and support to ensure they have the necessary knowledge and skill to effectively perform job functions with regards to reimbursements and cash management. The Executive Director has implemented and updated Internal Controls, in order to ensure proper processes are in place with regards to cash management. In addition, a Reimbursement Policy has been implemented, to ensure consistency of invoice management. The Internal Controls provide for three, separate points of contact, with regards to Cash Management. The Bookkeeper has implemented monthly account reconciliations and will continue to perform monthly reconciliations to ensure accurate reporting of invoices and any accounts receivable. The Bookkeeper will follow the recommended month-end and year-end closing procedures. Both, the Executive Director and the Bookkeeper, agree to confirm the proper timing of reimbursement requirements. Anticipated Date of Completion: Some items have been implemented, however the final date of completion will be 12/01/2025 Completed Responsible Party: Executive Director and Bookkeeper

Finding Reference Number: 2024-003 Description of Finding: Inaccurate Indirect Cost Rate Applied Statement of Concurrence or Nonconcurrence: The District concurs with the finding. Corrective Action: The District will use the correct overhead rate for future reporting. Name of Contact Person: F. X. Flinn, Board Chair, Telephone:(802)- 369-0069, Email: chair@ecvtd.gov Projected Completion Date: July 2025

Finding Number: 2024-042 Audit Type: Single Audit Finding Title: Misallocation of Expenditures Across Federal Awards Related Finding: 2024-028 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will revise its grant accounting procedures to ensure expenditures are properly allocated to the correct federal awards. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will implement additional review steps during the grant reimbursement process. 5. Status of Prior Year Finding This is a new finding.

Finding Number: 2024-032 Audit Type: Single Audit Finding Title: Delayed Final Reimbursement Due to Unresolved Agency Requests Related Finding: 2024-023 (Yellow Book) 1. Contact Person Responsible for Corrective Action Name: Shannah Weaver Title: City Clerk Department: Finance Department 2. Planned Corrective Action The City will designate a grants coordinator to monitor agency requests and ensure timely responses. 3. Anticipated Completion Date September 30, 2026 4. Management's Response Management concurs and will improve communication with funding agencies. 5. Status of Prior Year Finding This is a newt finding.

Ineffective Grant Management Recommendation: Establish a standardized process for reviewing grant budgets against actual expenditures, with clearly defined roles and timelines. Deliver targeted training to relevant staff on grant reporting protocols and variance analysis. Implement a cross-functional review procedure prior to report submission to ensure accuracy and completeness. Action Taken: Since migrating to the new accounting software in February of 2025, CMJTS program managers have better access to reporting for their budgets. Budgets are also loaded into the system by month, and program managers are then able to track program to date expenses versus the what had been planned. Additionally, CMJTS accounting staff has moved to ‘real-time accounting’, meaning that all transactions are being recorded right away in order to flow through to program manager reports. Additionally, the CMJTS Finance Manager meets with program managers on a monthly basis to review budgets and provide additional training. These additional steps empower the program managers to take ownership of their budgets and be able to make more informed decisions on running their programs.

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact Person Responsible for Corrective Action: Gregory Faust, Town Administrator Corrective Action: The Town of Bristol will take the following actions to address finding 2024-001: The Town of Bristol will adopt and implement Cash Management Policy that ensures compliance with federal requirements. This policy will cover drawdowns, disbursement timing, and reconciliation of federal funds. This policy will be reviewed and approved by Town Administrator and the Selectboard. Once the policy is adopted, training will be provided for all staff involved in managing federal funds. The Town will establish procedures for reviewing and reconciling balances and drawdowns. Anticipated Completion Date: January 1, 2026

Management’s Response: Although the Organization does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

Management’s Response: Although the Corporation does not currently use an interest-bearing account for project funds, due to the ongoing operation of the program and continuous activity within the project funds account, any interest earned in such an account would be negligible. Management is in the process of evaluating this recommendation to determine the appropriate course of action.

Finding 2024-001 (A/B – Activities Allowed or Unallowed and Allowable Costs / Cost Principles) US Department of Homeland Security Federal Emergency Management Agency (FEMA), Assistance Listing 97.036 COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) Name of contact person: Warren Pate, Vice President Finance Corrective action: The Vice President Finance will oversee repayment to FEMA a total of $79,118.82, representing invoices that were submitted for reimbursement more than once ($77,521.50), and an invoice for which reimbursement was requested greater than the invoice amount ($1,597.32). Additionally, a review of all project amounts planned to be submitted for future FEMA reimbursement will be conducted at the direction of the Vice President Finance, to ensure the completeness and accuracy of all project details. Proposed completion date: March 31, 2025

Recommendation: We recommend that the County implement a procedure by which a monthly review of the activities billed by providers to the CLTS Third Party Administration is performed with special attention on any authorized changes in services that occurred during the month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County acknowledges the recommendation to implement a procedure for monthly review of provider-billed activities submitted to the CLTS Third Party Administration (TPA). It is our understanding that the activity subject to testing in the future for CLTS will be case management and other services directly provided by Taylor County personnel. The County will evaluate current processes to make sure they are complying. Name(s) of the contact person(s) responsible for corrective action: Tracy Hartwig, Finance Director Planned completion date for corrective action plan: December 31, 2025

Processes and controls have been implemented so that the accounting staff prepares the grant reimbursement requests which are reviewed and approved by the CEO for submission.

Processes and controls have been implemented so that the accounting staff prepares the justification and expense support of the grant reimbursement requests which are reviewed and approved by the CEO for submission.

Cash Management - TCJFS will evaluate draws every week when a draw is available to do. Draws can be done anytime during the week but must be completed by Friday at 2:00pm. TCJFS will pull in vouchers to the CFIS system from the ledger system that TCJFS anticipates being paid by the Auditor’s Office. TCJFS will then run a cost allocation with the most current RMS numbers and then use the Over/Under Report to determine the draw amount. Draws should be taken from those allocations where expenses have hit or from an allocation where we are under-drawn. TCJFS should never have more than 10 days cash on hand at the end of a quarter.

The District agrees with the finding and through education and training of staff, the District is in the process of implementing procedures to ensure that all required reports are prepared accurately and agree to the activity recorded on the District’s general ledger.

Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2024 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Finding 2024-003 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management has deposited the underfunded amount as of the date of this report.

Finding 2024-002 – Monthly Reporting/Tracking of Government Grants Statement of Condition: MBCDC receives many cost reimbursement government grants with monthly reporting. During the audit process, MBCDC was unable to provide reports from the accounting software demonstrating the grants are fully utilized. These grants are subject to oversight and repayments could occur. Corrective Action Plan: MBCDC will update the grant tracking spreadsheets for federal funds and devote more resources to proper tracking procedures. Status: In process. Correction Action Completed For the year ended December 31, 2024, the audit disclosed no findings, questioned costs, or recommendations that were completed and required to be reported.

Condition: During the audit it was noted that there were some individuals who did not have documentation of the correct wage that was used ont he grant expenditure report. The Club also does not keep any copies of the invoices to back up which expenses are allocated to the grant. Plan: The Club plans to review the issue with its current procedures and revise them as necessary to provide better controls over grant expenditures. Anticipated Date of Completion: As soon as possible - before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have started to keep the documentation for each salary increase and review in the employee's personnel files and the supplies that have been purchased.

Condition: During the audit it was noted that, in the beginning of the year, employee timecards were missing. Plan: The Club will review their monitoring procedures to ensure consistent retention of employee timecards. Anticipated Date of Completion: As soon as possible - before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have reviewed our monitoring procedures to ensure consistent approval of employee timecards.

Condition: During the audit it was noted that instances of wages submitted for reimbursement for two Club employees were more than gross wages that should have been assigned to the grant based on the amount of the paycheck and the percentage allocation. Plan: The Club plans to review the issue with its current procedures and revise them as necessary to provide better controls over grant expenditures. Anticipated Date of Completion: As soon as possible - before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have evaluated our procedures related to grant reimbursement requests review and we are working on improving our current proceudres.

Management recognizes that there was inadequate documentation from multiple districts to support salary and benefit costs within the Title I Grants to Local Educational Agencies program. Also, Centennial BOCES recognizes, as the fiscal agent, that it is the entity responsible for compliance with the rules and regulations of the program, including for those activities taking place at each district. As a result, the Chief Financial Officer will work with the Grants Accountant that manages this program and the distribution of funds to these districts. Ultimately, corrective action will have several aspects: general training and education, targeted training and education for those districts needing more support, and follow-up with districts to ensure accountability and integrity with the rules and regulations surrounding finding # 2024- 001 cited in this single audit. The first level of corrective action will be sending resources by email to each district in our ESSA consortium. These resources will focus around the requirements of time and effort, in order to support salary and benefit costs charged to federal funds. These resources will contain informational content around time and effort requirements and citations to the Cost Principles, as well as examples and scenarios to guide districts through the proper process of documenting these costs. These emails will be to both the fiscal and program representatives at each district, and will take place in Fall 2025. Targeted support will be provided to those districts cited by the auditors as having insufficient time and effort documentation to support the salary and benefits charged to the Title I Grants to Local Educational Agencies program. In addition to the previously named elements, this will include scheduling meetings with the district fiscal representative, district program representative, CBOCES Chief Financial Officer, and CBOCES Grants Accountant. These meetings will take place either through a phone call, Zoom, or in person. In these meetings we will go over why the district documentation was deemed insufficient, and then have a conversation around the resources provided and how we can help bring the district into compliance and sustain that compliance going forward. These meetings will be scheduled during Fall 2025.As the final element of this corrective plan, CBOCES will ask districts to provide their time and effort documents that appropriately support the salary and benefits being charged during FY26. For districts with adequate documentation, we will ask for time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. For districts with inadequate documentation, we will ask for a sample of two months of time and effort documentation during the fiscal year to monitor progress. If sufficient, no further action will be required of the district. If insufficient, CBOCES will contact the district and work to remediate any inadequacies or questions. These districts will also be required to provide time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. Recognizing the timing of this single audit report, Centennial BOCES will need to address the current time and effort documentation at districts for FY25. Before training activities begin in Fall 2025, CBOCES will ask districts to provide their time and effort documents that appropriately support the salary and benefits being charged during FY25. If found to be insufficient, we will work with applicable districts to correct their documentation and prepare for training activities. This work will be tailored to the specific needs of each district. For future fiscal years beyond FY26, CBOCES will work to maintain compliance by asking each district to provide time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. Also, new fiscal and program representatives at districts will be provided with the training and education documents named in the second paragraph of this action plan.

2024-002 Cash Management Compliance Name of Contact Person: Missy Hyman, CFO Corrective Action: Winn Community Health Center, Inc. will train staff to ensure cash management requirements are followed. This includes tracking the status of the federally funded cash disbursements against the need to draw down funds on related grants. Proposed Completion Date: March 31, 2026

Management concurs with the facts presented by the auditor. However, we do not agree with the conclusion that there is a lack of adequate internal controls in the area of program reports and accounting records. The Bank, as a Subrecipient, performs the closing of the CDBG-DR SBF grants and records each transaction in a system provided by the Recipient and its consultants. The Administrative and Performance Reports referenced by the auditor are automatically generated from the grant management systems provided by the Recipient. The differences reflected between the Bank’s records and these reports result from a system error under the exclusive control of the Recipient and its consultants. These differences were duly reported to the Recipient and its consultants for correction.

2024-006 – WATERSHED REHABILITATION PROGRAM – LACK OF CONTROLS AND IMPROPER PERIOD OF PERFORMANCE – WRD – ALN 10.916 – MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition Pembina County Water Resource District applied costs to the Watershed Rehabilitation Program after the period of performance, which shows a lack of internal controls. The total value of the expenses past the period of performance end date was approximately $170,468 which occurred through September 14, 2024, more than a month past the period of performance end date. Corrective Action Plan: We agree we will ensure costs are in the proper period of performance going forward Anticipated Completion Date: FY2025