Corrective Action Plans

Views of Responsible Officials and Planned Corrective Action: The Arkansas Department of Education (ADE), Division of Elementary and Secondary Education (DESE), Health and Nutrition Unit (HNU), concur with the finding. The HNU implemented a new application and payment system that began in 2024. During implementation and subsequent operations, several issues with data transfers between the old and new system were identified and now corrected. The HNU Application and Finance staff will receive training to ensure that all criteria are met prior to the retroactive payment of claims. Anticipated Completion Date: April 1, 2025 Contact Person: Sheila Chastain Associate Director Arkansas Department of Education, DESE, Nutrition Services #4 Capitol Mall, Box #12 Little Rock, AR 72201 (501) 324-9502 Sheila.Chastain@ade.arkansas.gov Pamela Burton Director Arkansas Department of Education, DESE, Nutrition Services #4 Capitol Mall, Box #19 Little Rock, AR 72201 (501) 320-8978 Pamela.Burton@ade.arkansas.gov

March 24, 2025 In response to the finding, he Town hired a consultant to manage the High St Dam Project that was sourced with multiple grants. In FY2024, the Town was faced with a staffing shortage, and it did not properly oversee the reimbursement schedules. The Town anticipates this project to close out during the next fiscal year, and with new staff in place, it will properly manage and oversee all of the grant reporting and reimbursements. Sincerely yours, Laurie Guerrini, Finance Director

Views of Responsible Officials and Planned Corrective Action: Director of Child Nutrition will have a secondary person review claim before submitting to state department, to ensure accurate keying of data.

Finding 2024-002: Allowable costs and activities – significant deficiency in internal controls over compliance. Management Response Finding: Failure to Provide an Itemized Receipt for a Restaurant Purchase Corrective Action Taken: Effective July 1, 2024, CEN implemented Ramp, an expense management platform that ensures all purchases are documented with proper receipts before being charged to the grant. This solution directly addresses the issue of missing itemized receipts and ensures compliance with federal grant requirements. Steps Implemented: • Mandatory Receipt Submission: All purchases, including restaurant transactions, require an itemized receipt to be uploaded into Ramp before the expense can be approved. • Approval Before Grant Charging: An approver must review the itemized receipt to verify that no prohibited items were purchased before allowing the expense to be charged to the grant. • Grant Compliance Review: If an itemized receipt is not provided or contains unallowable expenses, the charge will not be allocated to the grant and must be covered by a non-grant funding source. • Training & Compliance: All employees who make purchases with grant funds have been trained on the requirement for itemized receipts and the consequences of non-compliance. Responsible Party: Kendall Guynes, CFO Completion Date: July 1, 2024 (Fully Implemented) Parties Responsible: Chief Executive Officer President Chief Financial Officer Business Manager The Corrective Action Plan is currently in place and was implemented on July 1, 2024.

Finding 2024-001: Allowable costs and activities – material weakness in internal controls over compliance and compliance finding. Management Response Finding: Lack of Documented Approval for Purchases. Corrective Action Taken: Effective July 1, 2024, CEN implemented Ramp, an expense management platform that ensures all purchases are documented and approved before processing. Ramp provides an automated and auditable approval workflow, ensuring compliance with federal grant requirements. Steps Implemented: • Centralized Purchasing System: All purchases are now made within Ramp using a Ramp credit card, ensuring complete oversight and control over spending. • Automated Approval Workflow: Each purchase requires approval within Ramp, and approvals are documented digitally, creating an auditable trail. • Receipt Verification: Every purchase must include a receipt, which the approver reviews before granting final approval. • Grant Compliance Review: Any charges that do not meet grant requirements are not charged to the grant and are instead assigned to an appropriate non-grant funding source. • Training & Compliance: All relevant staff members have been trained on Ramp’s approval and compliance procedures to ensure adherence to purchasing protocols. Responsible Party: Kendall Guynes, CFO Completion Date: July 1, 2024 (Fully Implemented)

Program: AL 93.778 – Medical Assistance Program – Special Tests and Provisions Corrective Action Plan: Program Integrity staff will continue to attempt to update cases at least every 30 days when case totals are at or below 25 and every 45 days when higher than 25. Trainings and regular conversations emphasize the need for descriptive narrative entries. As a result, the narrative entries will be more descriptive of the status of the case. For the exception reporting, the team continues to work on developing alternatives to using the reports in the Fraud Abuse Detection System. Concerning the misreported check, Program Integrity staff will give the Financial Team accurate information about collected refunds. The Department will ensure reports are accurate and make any necessary adjustments. Contact: Anne Harvey, Heather Arnold Anticipated Completion Date: 6/30/2025

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: The Agency is meeting with State Budget Office to discuss and review options for better separating future federal funding by fiscal year. This will allow for better tracking and transparency of drawdown times. Further, the Agency is aware of the finding for Award W91243-22-2-1001 (SAG 132) and currently reconciling all line items in the Award Program and year to determine and action on return of appropriate federal funding. Contact: Lauren Hargreaves Anticipated Completion Date: Ongoing

While all drawdown amounts were in alignment with incurred expenses, EF recognizes the importance of maintaining proper documentation to ensure compliance with federal cash management requirements. EF has established a formal practice requiring documented management approval for all drawdowns before they are initiated.

Recommendation – Auditors management to monitor and evaluate the performance of their accounting staff and to make improvements to prevent and/or detect noncompliance when necessary. Additionally, the Center should provide training to all personnel involved in accounting for federal awards. Action Taken – The Center hired and filled a key financial position subsequent to the year end. Management believes a lack of permanent staff a significant factor in causing this finding. The Center has established proper accounting procedures and controls, and with the key postion being filled, federal draw downs will be perfomed according the Center's policy.

Department of Justice Housing - Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreement with audit finding. Action taken in response to finding: All reimbursement requests will follow a process of review with back-up documentation prior to submission for all reimbursable grants. Contact person(s) responsible for corrective action: Joseph Padilla Planned completion date for corrective action plan: 3/1/2025

Corrective Action: Child Nutrition will incorporate separation of duties when calculating the reimbursement for meals. At least one on—site review of the meal counting and claiming system for each school. Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: February 18, 2025

Condition: There was no evidence of a system of internal control over the cash management requirements, including a written policy related to reimbursement of funds on a per-refugee basis. In addition, it was noted that reimbursement was requested prior to incurring expenses on a per-refugee basis. There were also refugee costs coded incorrectly within the general ledger. Planned Corrective Action: Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that individual refugee costs were coded to the correct general ledger account. Contact person responsible for corrective action: Linda P. Foster, CEO Anticipated Completion Date: Refugee ledger reconciliation process completed 2/1/2025 Policy approval and implementation to be completed by 5/1/2025

Finding 2024-002 Cash Management – Timeliness of Subrecipient Payments Plan: UIC - The University of Illinois Chicago will provide additional training and guidance to research administrators on the requirement of timely payments to subrecipients. UIUC – Sponsored Program Administration continues the development of a subaward invoice automation platform to create and capture efficiencies toward the 30-day payment requirement. In tandem, there is continual review of strategies to address the current manual, multi-layered approval and payment process. Expected Implementation Date: UIC - March 2025 UIUC - December 2025 Contact: Katrina Lopez, Assistant Director Office of Sponsored Programs (OSP) University of Illinois Chicago klopez3@uic.edu 312-996-3782 Karen Thomas, Director Post-award Sponsored Program Administration University of Illinois Urbana-Champaign Kthomas2@illinois.edu 217-265-4096

Finding: During a review of the awards population for fiscal year 2024, the University identified 6 accounts that had duplicate contact and bank information. After further investigation, these accounts were determined to be fraudulently created. In total, $54,112 in funds were paid out. The school worked with the U.S. Department of Education’s Cyber Incident Division to inform the Department of the fraudulent activity. Corrective Action Plan: Management agrees with the findings and has put the following in place. The Bursar will work with ITS to perform a scan of all students’ accounts for duplicate contact and banking information. If duplicates are found students will be notified and accounts frozen until students are identified. This will be critical before refund checks are dispersed to students every semester. The amount of $54,112 will be paid back with the next draw down before February 28, 2025. Responsible Officials and Implementation Date: The Bursar and Director of ITS will be responsible for this action plan and will implement by July 1, 2025, a scan done by the system. Bursar will spot check for duplicates until the report is built and put in place for the scan.

Corrective Actions: 1. Segregation of Duties for Cash Management: o Align the RAIS policy to requiring that all reimbursement requests be reviewed and approved by a second staff member before submission as other programs. o Utilize electronic workflow approvals to track submission approvals. o Target completion date: By the end of Fiscal Year 2025. 2. Formalized Written Procedures for Federal Drawdowns: o Develop and distribute a written standard operating procedure (SOP) outlining the review and approval process. o Provide staff training on the SOP to ensure compliance. o Target completion date: SOP finalized within six months. 3. Quarterly Internal Audit of Reimbursement Requests: o The finance department will conduct a quarterly review of drawdowns to ensure compliance with federal guidelines. o Maintain documentation of all approvals and reconciliations in an audit-ready format. o Target completion date: First review within the next quarter. Responsible Staff: Senior Director of Grants in conjunction with Chief Financial Officer

U.S. Department of Housing and Urban Development Cicero Commons Senior Housing Development Fund Company, Inc. (Lucille Manor Apartments), HUD Project No. 014-EE070-NY06-S941-009 respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: July 1, 2023 – June 30, 2024 The findings from the 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2024-001: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 Condition: The required deposit of $7,387 for the year ended June 30, 2023 was made after the 60 day deadline. Recommendation: Lucille Manor Apartments should ensure residual receipts are made within 60 days of year-end in accordance with the HUD Regulatory Agreement. Action Taken: The required deposit was made in March 2024. Completion Date: March 2024 Name of Contact Person Responsible for Corrective Action: Kyle Lyskawa, CFO, (315) 424-1821.

2024-001 – Reporting Federal Agency: U.S. Department of Energy Federal Program: 81.042 Weatherization Assistance for Low-Income Persons Responsible Official Jennifer Beloff, Chief Program Officer Plan Detail Action is in the process of enhancing its internal controls over reporting to ensure that only federally related costs and activities are reported within its Federal programs and training its employees on its internal controls. Anticipated Completion Date March 2025

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Material Weakness Summary of Finding: There is no administrate review of reimbursable expenses submitted to MAESSU by the district payroll clerks. Lack of an internal control. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Clerk will submit the reimbursement requests to the corporation Business Manager for review before the reimbursement is submitted to MAESSU for payment. Anticipated Completion Date: The anticipated completion date will be with the April reimbursement submission.

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Illinois Office of Emergency Management Federal Financial Assistance Listing #97.036 Program Name: Disaster Grants – Public Assistance Finding Summary: The Cooperative did not retain documentation to support the review and approval over material costs claimed for reimbursement under the program. Responsible Individuals: Scott Seipel (Warehouseman), Ryan Ruppel (Superintendent) Corrective Action Plan: A line or lines will be added to the material charge out sheet to formalize the review and approval. The Superintendent of Operations will begin reviewing and approving all material charge out sheets and documenting that review to supplement the review currently being done by the Warehouseman when entering the material charge out sheets prepared by other employees or contractors. Anticipated Completion Date: We believe this corrective action plan can be reasonably incorporated into our internal controls by June 2025 and will make necessary arrangements to ensure that it does get incorporated.

Name of contact person: Mr. Joseph Gudac, Business Manager Corrective Action: We will follow our policy for ensuring the accuracy of meal counts before remitting the total meals to PDE. The district will implement a pre-submission review protocol to verify that monthly claims accurately reflect the meals served to eligible students. We also will develop a standardized checklist for reviewing and approving meal counts before submission and to ensure that discrepancies identified during review are promptly investigated and corrected. Anticipated Completion Date: The District will implement the above procedure immediately.

Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to verify account updates; • Limited the amount of per vendor/subrecipient daily payments to our insurance limits, with verifications prior to releasing additional funds when the total payment exceeds the insurance limits; • Subrecipient payment receipt is verified by both the subrecipient and the Commons grants team; • Updated our policy and procedures to direct our subrecipients to request banking changes through our procurement system and not through email; and • Expanded implementation of our Kissflow procurement system across the organization, which includes new vendor process as well as a change of vendor information module. Vendor changes would be approved first by the program/department that works with the vendor prior to Finance approval. Completion Date With the exception of implementing the change of vendor information module in Kissflow, the above actions have all been completed by the date of this report. The projected completion date for Kissflow change of vendor information module is April 30, 2025. Responsible Party Dana Thomas, Chief Financial Officer Angela Allen, Vice President of Finance

Recommendation: The Organization should prepare and file its Financial Status Reports within 10 days following the close of the reporting month. Views of Responsible Officials and Planned Corrective Actions: The Organization agrees with the finding. All Financial Status Reports will be prepared and filed by the Executive Director within the required timeline. The Executive Director will ensure that the reports are prepared within a reasonable amount of time in order to allow for a review process.

Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has developed a system to identify which subrecipients are subject to required audits and are tracking subrecipients to ensure timely submission of required audit reports and appropriate corrective actions. Contact Person: Wayde Sick, Director and Executive Officer and Gwen Ferderer, Finance Director Anticipated Completion Date: August 2024

Department of Public Instruction Response/Corrective Action Plan: We agree with the issues identified. 1. NDDPI acknowledges the late reports in FSRS.gov from October 2022 to September 2023. As stated in the finding, the reports were initially reported, but according to the Helpdesk with FSRS.gov, they required removal to re-submit using the corrected FAIN numbers. NDDPI administrators were not aware that the reports initially filed would be deleted from the records, versus the incorrect reports becoming labeled as inactive and saved for historical purposes. Kim Vega, Administrative Officer with NDDPI will review current archive processes and determine where changes may be needed. The FSRS website will be eliminated as the reporting application for FFATA in the Spring of 2025, and from that time forward, will be performed in the SAM.gov application. Currently, NDDPI administrators are participating in training and presentations for the test website and will continue to watch for any changes to administrative tasks. An introduction of the new website’s capabilities did address enhancing the feature for deleted reports as a part of the user’s tasks rather than the Helpdesk’s responsibility. NDDPI will continue to follow this development while in training for SAM.gov reporting. With the changes in application sites, the future enhancement in ND Foods will include an Application Programming Interface (API) for FFATA reporting. This API will provide the capability of real-time reporting, eliminate most manual tasks, increase report accuracy, and improve team member productivity and efficiency. The new website also mentions the zip code validation as an upgraded process. This process in the current system has been an intense time drain for staff members who enter FFATA by manual entry or batch upload, so improved functionality in this area is a much-needed upgrade. 2. NDDPI acknowledges the submission of the late report leading up to March 2024 as stated in item number 1. Reports for the meal claims were not reported in FSRS.gov until the FAIN numbers and programming were corrected in ND Foods, and a new Excel report was written with the corrections. Therefore, the report was not submitted within the required deadline. NDDPI Administrative officer worked with the Child Nutrition Administrative Staff Officer and NDIT programmers to correct the programming and process new reports for batch upload. 3. NDDPI acknowledges the missing reports for November and December 2023. During the transition from one claim year to the following, multiple reports must be run in ND Foods to complete the block FFATA reports. In 2023, NDDPI administrators were not aware of the overlap of claim years and how it would affect reporting, and therefore, only the current-year reports were processed. Currently, ND Foods has been upgraded to include an automated feature for FFATA reporting to include the final claims from the prior year and the new year’s claims in its reports for batch upload. Every effort was made to report both the old claim year and the new claim year in 2024. 4. NDDPI administrators have reviewed the reporting dates and the obligation date for claims in the CN block reporting, and we have agreed on the federal guidance which indicates the awards are obligated in advance will have the date of signature or acceptance at NDDPI, and the batch upload for payments made to an award will have the action or obligation date of the approval date for payment. This process will correct the reporting dates for claim payment processing (10.559, 10.555, 10.558, 10.556, 10.553) or reporting month for an obligated award (10.582) and its required obligation date. NDDPI staff members should be able to test and implement a programming change in our current reporting system in the next 2 months. If this change proves to be more intense than planned, we will wait on a quick fix until the upcoming interface upgrade with Sam.gov. We know the interfacing upgrade will require an even greater amount of time, energy, and money, and it will be a change we must complete; therefore, if the quick fix proves to be ineffective and time-consuming, the change in reporting will wait until the programming begins for the API Interface. Currently, federal officials are reporting the transfer between reporting sites will be ‘Spring of 2025’ but are not giving users a specific date. We have consolidated the coordination of FFATA reporting to a single individual rather than having each area do their own. We will prepare and implement procedures for the FFATA reporting. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: June 30, 2025

Office of Management and Budget Response/Corrective Action Plan: The Office of Management and Budget agrees with this finding. OMB agrees but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. Contact Person: Elizabeth Roger, Account Budget Specialist Anticipated Completion Date: December 2026