Corrective Action Plans

Finding 2024-002 Grant Budget Management Corrective Action Plan: Kankakee County Community Services, Inc. has implemented a comprehensive system to manage its grant budgets efficiently. Following the restructuring of its fiscal department and the engagement of an accounting firm, the organization established a robust, holistic process for overseeing all grant-related finances. Central to this approach is a budget monitoring calendar, which outlines key dates for report submissions, budget deadlines, and grant renewal periods. This calendar is accessible to all managers, fiscal staff, and the executive team, ensuring everyone remains informed of critical timelines. The Executive Director conducts weekly meetings with the senior leadership team to review ongoing tasks and discuss budget updates. During these meetings, the consultant CFO presents detailed reports on both required actions and the expenditures for each program. Person(s) Responsible: Mr. Anibal Vega Timing for Implementation: 3/1/2026

Finding 2024-001 Internal Controls over Financial Reporting and Late Filing of Data Collection Form Corrective Action Plan: Kankakee County Community Services, Inc. has reorganized its fiscal department to strengthen compliance with regulatory accounting standards. The organization engaged an accounting firm to assist in updating and restructuring its accounting policies and procedures. An accounting calendar was established to guide the fiscal team in preparing and maintaining internal controls as well as reporting requirements. Additionally, the board of directors’ finance committee convenes on the fourth Monday of each month to review all fiscal operations. Person(s) Responsible: Mr. Anibal Vega Timing for Implementation: 3/1/2026

2024-005 UNIFORM GUIDANCE AUDIT REPORTING REQUIREMENTS Federal Agency: Department of Transportation Federal Program: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listing Number: 20.509 Federal Award Identification Number and Year: MN-2020-020-01 Pass-Through Agency: Minnesota Department of Transportation Pass-Through Number: MN-2020-020-01, MN-2023-045-00 Award Period: Year Ended December 31, 2024 Compliance Requirement: Cash Management Type of Finding: Material Weakness in Internal Controls over Compliance Recommendation: The deadline for filing an audit report with the Federal Clearinghouse is 30 days after receiving the audit report or 9 months after year-end, whichever occurs first. It is recommended that prior to year-end, the operation board annually approve an audit schedule timeline. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Transit Board will annually approve a schedule and timeline prior to year-end. In addition, the Transit Board has hired new external auditors who will have sufficient resources to complete the audit by the September 30, 2026 deadline for the December 31, 2025, audit. Name of the contact person responsible for corrective action: Cecilia Mutharia, Transit Director Planned completion date for corrective action plan: June 30, 2026

2024-004 INTERNAL CONTROLS OVER CASH MANAGEMENT Federal Agency: Department of Transportation Federal Program: Formula Grants for Rural Areas and Tribal Transit Program Assistance Listing Number: 20.509 Federal Award Identification Number and Year: MN-2020-020-01 Pass-Through Agency: Minnesota Department of Transportation Pass-Through Number: MN-2020-020-01, MN-2023-045-00 Award Period: Year Ended December 31, 2024 Compliance Requirement: Cash Management Type of Finding: Significant Deficiency in Internal Controls over Compliance Recommendation: It is recommended the Transit Board designate qualified personnel for conducting the quarterly reporting review. The review should be performed and documented. Formal procedures should be documented to ensure consistency and effectiveness of the quality review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Transit Board will continue to evaluate their internal staff capacity to determine if an internal control policy over cash management and other areas is beneficial. Name of the contact person responsible for corrective action: Cecilia Mutharia, Transit Director Planned completion date for corrective action plan: June 30, 2026

Corrective Action Plan: The City of Chicago impedes the submission of expenditure reports by delaying the finalization of budgets or by not allowing GCI to submit expenditures when a budget change is submitted during the period when the change is approved. GCI will submit required expenditures upon execution of City contracts and will update them on time. Estimated Correction Date: GCI does not currently have any City contracts. When GCI enters into new City contracts, GCI will submit expenditures in a timely manner if the proper City documentation is available to complete the tasks. GCI has a new full-time Operations Manager, who will submit expenditures. Having a full-time manager familiar with all the expenditures and processing should make this task easier and timelier. Responsible Official: Nedra Sims Fears, Executive Director

Finding 2024-003 – Career and Technical Education - Perkins CFDA No. 84.048 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Condition: During our test of controls over compliance with cash management requirements as it relates to the Career and Technology 2023 AL No. 84.048 we discovered that in multiple instances requests for funds (Form RF-1) related to the grant was not based, as much as possible, on actual expenditures, rather than what is obligated. Criteria: Title 34 of the Code of Federal Regulations Section 80.20: Standards for financial management systems requires the following: (b) The financial management systems of other grantees and subgrantees must meet the following standards: 1) Financial reporting. Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or subgrant. 2) Accounting records. Grantees and subgrantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or subgrant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income. State Finance Regulations • Form RF1 for requesting funds through an on-line process has been developed to document the Department's distribution of funds on an "as needed" basis. The requests should be based, as much as possible, on actual expenditures, rather than what is obligated. Unexpended balances should not exceed 10% of funds received to date for any DESE administered grants. It is incumbent upon grant recipients to observe their expenditures closely and submit their RF1 forms within the designated timeframe, usually the last two weeks of the month, for requesting cash advances. Grant recipients may make requests in excess of the allotment schedule but must include a justification explaining the need for additional funds and additional documentation may be required. By submitting a request the grantee certifies that the request is in compliance with the "Cash Management Act" (31CFR part 205) and EDGAR regulations (34 CFR part 80.20 and 80.21), which allow for cash advances provided grantees maintain procedures to minimize the time elapsing between the receipt and disbursement of grant funds. Additionally, the grantee certifies that the obligations incurred under this project for which funds are requested, were made within the period of availability (project duration) stated in the grant award notice. The grant records in support of each request must be in sufficient detail to properly substantiate all claims for payment and expenditures made under the grant. Effect: Cash balances in excess of needs may be earning interest in excess of federal guidelines and would need to be returned. Questioned Costs: None Context: During our test of cash disbursements for the Career and Technology 2023 Final Request for Funds indicated fully spent however the grant was not fully spent as of 10/30/23. The School had to return the drawdown on 10/30/23 which also included additional unspent funds on 1/10/24. Cause: In June 2023 Assabet’s staff member handling grants retired. They only came in once a week to help with grants until new staff could be hired. In October of 2023 our current grant manager was hired and had very limited training on grants before the retiree quit fully in January 2024. Due to this, training in Edgrants was extremely limited and the FY23 grants mentioned where not handled correctly. Identification as a Repeat Finding: This is a not a repeat finding. Recommendation: The grantee’s administrative staff should establish procedures to ensure compliance with the cash management requirements as described in 31 CFR part 205. These procedures should include a thorough review of cash needs based on expenditures incurred as of the date of an anticipated draw down and how quickly those related liabilities are anticipated to be liquidated through the normal warrant (bill) payment process. Responsible for Corrective Plan: Sabrina Howley Estimated Completion Date: 11/5/25, Ongoing Action Taken: Going further no funds will be requested unless they have been expensed.

The Organization hired a new grant and partnership specialist. This specialist reviews all draws to ensure that the draw is for reimbursement for actual expenditure and not estimated expenditure. Reports and draws are also reviewed by the vice president of finance.

Audit Response to Finding 2024-002 to Uniform Guidance Audit - Advanced Drawdown Acknowledgement and Concurrence: Management acknowledges that two out of the six drawdowns selected for testing within the Research & Development (R&D) cluster were requested prior to the actual incurrence of the underlying expenditures. The University identified that the noncompliance was timing related only. A full year of stipend expenses were advance recorded in the general ledger and triggered the drawdown process prematurely. The University determined that this was an isolated incident unique to only one of the federal awards, and this issue has subsequently been corrected. While the grant was ultimately in a cumulative underdrawn position by year-end, we recognize that the reimbursement method under Uniform Guidance requires expenditures to be paid or incurred prior to the request for federal funds. Corrective Action Plan: • Enhanced Management Review: The University Controller’s Office will perform a "secondary review" of the GL date of the underlying expenditure versus the drawdown request date to ensure no "future-dated" or "anticipated" costs are included. • AP Policy Change: The University has revised its stipend processing workflow to ensure that payments are scheduled according to the service period rather than the entry date, and no longer will 12 months of stipend payments be entered in AP at one time. Responsible Party: Joseph J. Piccirilli, Chief Accounting Officer and Controller Completion Date: March 2026

Follow administrative costs cap guidelines for projects.

View of Responsible Officials: ICMEC discovered an error during FY2024 that resulted in overdraws for their Federal awards as well as drawing expenses from one award that should have been drawn under a different award. After meeting with the funder, ICMEC began to reduce its draws to reduce the overdraw balance. Additionally, ICMEC has received a modification and extension to one of its grants that allows for retroactive indirect and salary costs. As of 8/31/25, the net balance of all JTIP grants combined is close to zero. We are working to correct the individual balances.

Finding Type: Compliance with Uniform Guidance Requirements. Name of Contact Person: Mr. David Wyman, City Administrator, (573) 624-5959. Recommendation: We recommend the City develop written policies and procedures related to cash management, cost allowability, procurement, and conflict of interest provisions for federal funds it received. Corrective Action: We have already adopted the appropriate policies. Proposed Completion Date: Immediately.

Management acknowledges the need to streamline the fund reconciliation process and plans to improve.

Finding 2024 – 005 Lack of Individual with appropriate skills, knowledge, and experience Name of Contact Person: David Rosado, Executive Director Corrective Action: The Council agrees with this finding. The Council has hired a new Finance Director effective January 02, 2025, with the appropriate skills, knowledge, and experience to oversee the Finance Department. The Finance Director has identified and corrected internal control issues. Completion Date: May 19, 2025

The department will adopt written policies with the Uniform Guidance for federally funded grant programs accepted by the department.

JFS is in the process of hiring a new Chief Financial Officer (CFO) with pertinent experience for non-profits, governments, and billing. That person will lead the finance team to ensure best accounting and internal control practices are implemented and followed. During 2025, JFS strengthened its governance and internal control environment by implementing a centralized system for tracking all grant-related data in a single, secure location. All grant documentation is now maintained electronically within the organization’s OneDrive system, improving record retention, transparency, and audit readiness. The Finance Department established regular internal finance meetings, in addition to standing leadership meetings, to promote consistent communication, segregation of duties, and oversight across the finance function. Management continues to provide the Finance Committee of the Board with monthly financial reports; supporting ongoing fiscal monitoring and informed decision-making.

Condition: The board of education designated a limited number of individuals to authorize transactions. However, a signature stamp with the signatures of the board designated individuals was available for use by non-designated individuals. Plan: The District will stop the use of signature stamps to approve purchase orders and sign payment remittances. Anticipated date of completion: June 30, 2026. Name of contact person: Dustin Day, Superintendent. Management response: We no longer use signature stamps. All purchase orders and payment remittances are signed manually by the designated individual.

Finding Number: 2024-005 Anticipated Completion Date: March 31, 2026 Responsible Contact Person: Brad McCain, Chief Financial Officer Planned Corrective Action: Management is strengthening controls over tracking, documenting, and reconciling federal grant expenditures to ensure compliance with period of performance requirements. Actions include implementing improved grant-level tracking within the financial system, reconciling general ledger activity to reimbursement invoices and the SEFA on a routine basis, and retaining documentation to support the allowability and timing of costs charged to federal programs. Management will also formalize procedures for payroll reallocations across programs to ensure traceability and compliance with grant requirements. Documentation will be required to be attached to all journal transactions demonstrating the linkage between the underlying payroll records to the correct grant programs.

Higher Education Institutional Aid– Assistance Listing No. 84.031 Condition: The institution did not have effective internal controls over cash management. Recommendation: We recommend the institution review and implement their internal controls and procedures over cash management so that expenditures are being properly tracked, reconciled, and reviewed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Drawdowns are currently prepared by one individual and reviewed by separate individual, however the supporting documentation does not consistently reflect that two individuals were involved in the drawdown; the procedures will require the sign off of both the preparer and the reviewer on the draw down documentation. Name(s) of the contact person(s) responsible for corrective action: Jeff Copeland Planned completion date for corrective action plan: March 31, 2025

Uniform Guidance Corrective Action Plan Management acknowledges that improvements were necessary in assuring that drawdowns of grant funds are in compliance with regulations. Accordingly, drawdowns of grant funds will be more aligned with bi-weekly and/or monthly expenditures as supported by an analysis of payroll and accounts payable system activity by the Chief Financial Officer prior to authorizing any drawdowns. Additionally, requests for drawdowns will be reviewed by a member of the Finance Team to assure that it is within acceptable parameters related to grant spending. This process revision will be implemented no later than March 31, 2026.

In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to increase the return on available funds. The Authority intends to develop and adopt formal written procedures for cash management and investment monitoring during the next fiscal year.

Finding 2024-004 – Insufficient Skills, Knowledge and Training, and Leadership (Material Weakness) Name of Federal Agency: U.S. Environmental Protection Agency Federal Program Name: Nonpoint Source Implementation Grants Assistance Listing Numbers: 66.460 Pass-Through Entity: Oregon Department of Environmental Quality Name of Federal Agency: U.S. Department of Commerce – National Oceanic and Atmospheric Administration Federal Program Name: Pacific Coast Salmon Recovery Program Assistance Listing Numbers: 11.438, 15.015, 15.244 Pass-Through Entity: State of Oregon – Oregon Watershed Enhancement Board (OWEB) Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: National Fish and Wildlife Foundation Assistance Listing Numbers: 10.665 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of Agriculture Federal Program Name: Natural Resources Conservation Service Assistance Listing Numbers: 10.905 Pass-Through Entity: U.S. Forest Service Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Wildlife, Sport Fish and Restoration Program Assistance Listing Numbers: 15.244 Pass-Through Entity: Bureau of Land Management Name of Federal Agency: U.S. Department of the Interior Federal Program Name: Secure Rural Schools and community Self-Determination – Watershed and water-quality improvements Assistance Listing Numbers: 15.234 Pass-Through Entity: Bureau of Land ManagementCriteria: Under Uniform Guidance 2 CFR §200.303, non-federal entities must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the award terms and conditions. This includes ensuring that:  Personnel administering federal awards possess adequate skills, knowledge, and experience.  Management and leadership provide appropriate oversight of federal award activities.  Financial management systems adequately support accurate reporting, documentation, retention, and reconciliation of federal expenditures in accordance with 2 CFR §200.302. Condition: During the audit of federal awards, the entity did not demonstrate sufficient skills, knowledge, or experience of the staff and leadership responsible for administering and overseeing federal programs. Specifically:  Adequate supporting documentation for federal award expenditures was not maintained or provided.  Leadership oversight of federal award compliance activities was limited, and management review of grant activity were not evidenced. These conditions resulted in weaknesses in financial reporting, compliance monitoring, and documentation related to federal awards. Cause: Partnership for the Umpqua Rivers has not ensured that staffing levels, qualifications, and experience are sufficient to support federal award administration and compliance. In addition, leadership lacks adequate knowledge of federal award requirements to provide effective governance, oversight, and monitoring of compliance activities. Formal training and documented procedures for federal awards management have not been prioritized. Effect or Potential Effect: As a result of these deficiencies:  Partnership for the Umpqua Rivers is at increased risk of non-compliance with Uniform Guidance requirements.  Federal expenditures may be unsupported, inaccurately reported, or unallowable.  Errors or compliance violations may not be detected or corrected in a timely manner.  The entity may be subject to questioned costs, repayment of federal funds, or additional scrutiny from grantor agencies. Questioned Cost: None identified Context: During our audit, it was found that the Partnership for the Umpqua Rivers experienced complete staff turnover in Financial Management for the year being audited. No current finance employees had worked for the organization during the year being audited. No financial files for Accounts Payable, invoices, or reporting were available to the current financial staff. Not adequately retaining supporting documents and invoices to support the expenditures of the general ledger and requests for reimbursement for grants, the organization records may be insufficient for testing and review, for internal controls or meeting federal documentation and reporting requirements. Repeat of a Prior-Year Finding: No, Prior- year did not require a Single Audit. Recommendation: We recommend that Partnership for the Umpqua Rivers:  Ensure staff responsible for federal awards receive appropriate training on Uniform Guidance requirements, grant financial management, documentation, and compliance monitoring. Assign federal award oversight to personnel with sufficient experience and qualification or obtain external grant management and accounting support as needed.  Establish written policies and procedures for federal award administration, including expenditure documentation, reconciliation, compliance review, and management approvals.  Require leadership to perform and document periodic oversight and monitoring of federal awards, including review of reconciliations reimbursement requests, and compliance metrics.  Implement ongoing monitoring and internal control assessments to ensure compliance with federal award requirements. District Response: Partnership for the Umpqua Rivers acknowledges the deficiencies. Corrective Action Plan: _____________ (To be completed by Partnership for the Umpqua Rivers) Planned Implementation Date: ___________ Responsible Person: Partnership for the Umpqua Rivers Finance Manager

Finding: 2024-003 Material Weakness in Internal Control Over Allowable Costs/Cost Principles and Reporting – WIC Special Supplemental Nutrition Program for Women, Infants, and Children, and Immunization Cooperative Agreements (10.557, 93.268) Corrective Action: We will work to ensure that the proper indirect cost rate is applied to the various grants. Proposed Completion Date: February 28, 2026 Name of Contact Person: Tomiko Fisher, Chief Operating Officer

2024-005 Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of participant eligibility, we selected a sample of 40 participants receiving meals at centers contracted with the CBS Food Program. For 2 of the 40 participants, management was unable to provide complete and valid eligibility documentation. In one instance, the only available eligibility form had been prepared in a future fiscal year, and in another instance, the eligibility form could not be located at all. Recommendation: We recommend that management strengthen its CACFP eligibility documentation procedures to ensure that all required forms are properly completed, collected, and retained for every participant. This should include implementing a standardized intake process, maintaining timely reviews to confirm completeness of eligibility files, and developing a tracking or monitoring system to identify missing or outdated documentation. Management should also reinforce internal expectations for timely updating of eligibility files and ensure staff are trained on CACFP documentation requirements. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: On February 1, 2025, Community Benefit Solutions rolled out the KidKare software system wide. KidKare is a CACFP software that allows Community Benefit Solutions to digitally process all eligibility-documentation, standardize the enrollment procedures, ensure forms are completed in accordance with the relevant regulations, request updated documentation upon the expiration of enrollment forms, and digitally store all the eligibility related information for all participants. Planned completion date for corrective action plan: June 30, 2025

City of Parker Management’s Corrective Action Plan For the Fiscal Year Ended September 30, 2024 Financial Statement Finding Number: 2024-101: Reimbursement Requests were Not Formally Approved by the City Prior to Submission Planned Corrective Action: The City will update its procedures to require documented City review and approval of all reimbursement requests prior to submission to a grantor. The City will also clarify responsibilities with the consultant to ensure submission and acknowledgment are independently performed and appropriately documented. Anticipated Completion Date: 09/30/2026 Responsible Contact Person: Kimberly Dalton, Bookkeeper

We concur with this finding. The County of York has hired a Human Services Director of Finance to assist with improving systems and financial processes within the Human Services (HS) divisions. The HS Executive Director and Director of Finance are recommending engaging an expert Consultant to assist the County’s Children & Youth Fiscal team in getting caught up on internal system timelines, as well as delayed reporting. The Consulting company will also be working to adequately train the Children & Youth Fiscal team for development purposes.