Corrective Action Plans

Finding 2024-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2025. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

Management Response: Due to the size of LDSC’s administrative staff, complete segregation of duties is not economically feasible. We will ensure the areas recommended above are added to our current policy to the extent it is economically feasible.

Auditor recommendation: We recommend that the City establish policies and procedures for requesting reimbursement of grant expenditures on a monthly basis, including reconciliation of the expenditures and reimbursements under each grant. Views of Responsible Officials and Planned Correc􀀁ve Ac􀀁on: The City agrees with this finding. Vacancies in key posi􀀁ons including the Airport Manager and the Transit Director of Administra􀀁on meant that there was not sufficient exper􀀁se in the program areas to ensure that reimbursement requests were prepared and submi􀀂ed 􀀁mely. These key posi􀀁ons have now been filled. The City now has an Airport Manager with substan􀀁al experience managing municipal airports and overseeing federal funding for airports. The City also hired a Transit Director of Administra􀀁on with extensive federal and state grant management experience, and exper􀀁se in Transit programs. The Accoun􀀁ng Officer, Grants Manager and Accoun􀀁ng Financial Analyst posi􀀁ons in the Finance Department have been filled, and the Grants Division is now fully staffed. More robust staffing is allowing Finance to perform more oversight in addi􀀁on to working more closely with Transit and Airport program staff. Filling these key posi􀀁ons and retaining qualified staff is essen􀀁al to establishing a process for 􀀁mely requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursement under each grant. The Transit Division is working with a contractor provided by the FTA on establishing policies and procedures to ensure compliance with federal grant requirements. This contractor is also providing training and technical assistance to the Transit program. The scope of this work includes ensuring requests for reimbursement of grant expenditures are submi􀀂ed 􀀁mely, and reconcilia􀀁ons of grant expenditures and reimbursements are completed 􀀁mely and accurately. The Airport Department is in the process of contrac􀀁ng with a vendor to assist with federal compliance and provide training for Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include helping with developing and documen􀀁ng policies and standard opera􀀁ng procedures for requests for reimbursement, and reconcilia􀀁on of expenditures and reimbursements. Addi􀀁onally, the Airport Department plans to create a Grant Accountant posi􀀁on which will be responsible for reconciling grant expenditures monthly and processing reimbursement requests quarterly. In CY25 the City plans to provide Uniform Guidance training for staff which will include internal controls related to cash management. Responsible Official:Emily Oster, Finance Director, James Harris, Airport Manager, Airport Heavy Equipment Mechanic, Gabrielle Chavez, Transit Director of Administration, Matthew Bonifer, Accounting Officer, Erika Lujan, Grants Manager Timeline and Es􀀁mated Comple􀀁on Date: June 30, 2025

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

Over the past year, CAPNC has continued to make significant improvements to its fiscal practices, particularly in navigating the software conversion from an archaic, unsupported system to Sage Intacct. This new software has modernized and deployed the levels of internal controls that were previously missing due to inadequate fiscal personnel oversight and technical capability. Current staff have been trained under Sage Intacct and Wipfli consultants to properly track accounts payable (A/P), accounts receivable (A/R), payroll, and grant management, ensuring data integrity and compliance. Resulting journal entries are in place to bring system in alignment and current as of July 2024, alleviating any further discrepancies related to past staff and old software. The old system will be archived as required under retention. To further stabilize and formalize these improvements, a Certified Public Accountant will be added as a consulting CFO. This role supports the ongoing development of fiscal operations. Additionally, it is recognized that the payroll vendor, ADP, was initially slow to address issues with uploaded data when notified by CAPNC, responded officially after CAPNC alerted repeatedly that it had now elevated to an audit issue. This issue has since been remedied. Staff have shown marked improvement over previous legacy staff in documentation, accountability, and monitoring. Payroll services in general are able to provide real-time features and accountability for time, resulting in more accurate, reliable, and allocable time recording. Payroll records are reviewed, and time studies are performed for all staff to ensure the allocation methodology is appropriate, consistent, and aligned with staff performance. Wipfli Consulting is providing technical assistance over an additional contract period to update policies and procedures for the fiscal area, in accordance with Uniform Guidance, and allow for advance reporting, as well as provide CPA support. The curriculum includes comprehensive training for all administrative leadership staff, covering fiscal oversight, grants management, and compliance. Allocations are regularly reviewed by the leadership team to ensure appropriate methodology and consistency with grant expectations and regulations. Board members have access to the accounting software through a Board portal for further oversight, enhancing transparency and accountability. Review of finance in conducted monthly by Board of Director’s Finance Committee.

Audit Finding Number: 2024-002 – Cash Management Agency: Public Housing Capital Fund Responsible Person, Title: Stephanie Schmutzer, Accountant Completion date: 7/1/2024 Agency Response: Concur Corrective Action Plan: Management concurs with the recommendation to implement timely LOCCS fundings that coincide with our normal accounting cycle and when directed by HUD to circumvent the rules to get that in writing not just verbal.

Finding 2024-005 Non-cooperation with IV-D Referrals Name of contact person: Corrective Action: July 1, 2024 Section II - Financial Statement Findings (continued) Kim Grissom, Family and Children's Medicaid Supervisor and Shelia Morton, Family and Children's Medicaid Supervisor Error discovered was that there was no IV-D Referral sent to Child Support Services. Family and Children’s Medicaid leadership updated the Recertification Documentation template on 11/20/2024 to ensure that workers are documenting the necessary IV-D Referral process (including when it is not required) on every case. The AP section of the template has been updated to allow caseworkers to provide detailed information on IV-D Referrals. All Family and Children’s Medicaid caseworkers have been advised to utilize the updated Recertification Documentation Template effective immediately. Currently, the Division of Health Benefits (DHB) have advised that during the Public Health Emergency and the Continuous Coverage Unwinding period, IV-D Referrals are not required and are only sent at the request of the client. This policy will be in effect until further notice from DHB (Admin Letter 13-23). Although IV-D Referrals are currently suspended per DHB, Family & Children’s Medicaid leadership will review this policy with staff by conducting a refresher training by 12/31/2024. The Family and Children Medicaid Supervisors created and utilizes an Error Trends Data log that went into effect on 10/1/2024. The Error Trends Data log will provide Family and Children’s Medicaid leadership with data regarding errors that are repetitive. This will help leadership conduct monthly or quarterly refresher training as well as individualized training for staff who continue to have repetitive errors. Staff who fail to utilize the updated Recertification Documentation Template and continue to have repetitive errors will be placed on a corrective action plan.For the Year Ended June 30, 2024 Corrective Action Plan Proposed completion date: Finding 2024-006 Inadequate Request for Information Name of contact person: Corrective Action: Proposed completion date: Finding 2024-007 Inaccurate Information Entry Name of contact person: Refresher training will be held by December 31, 2024 on effective documentation and record keeping. “Vehicle Status Documentation” template will be created and implemented by December 31, 2024. Error Trends Data log was implemented October 1, 2024. Adult Medicaid Lead Workers will monitor this by conducting a random selection of second party reviews each month. Adult Income Maintenance Supervisor II (pending vacancy), Delta Elliott, Income Maintenance Lead Worker III, and Michelle Ogle, Income Maintenance Lead Worker III Error discovered where vehicle status was not clearly documented in the case record caused by ineffective record keeping and incomplete documentation. Refresher training will be held by 12/31/2024 to review appropriate documentation and record keeping in NC FAST and will be conducted by Adult Medicaid leadership. Adult Medicaid Supervisor will create a “Vehicle Status Documentation” template that will be utilized by all Adult Medicaid caseworkers at every application and recertification. Completion and uploading of this template will be required in NC FAST. Adult Medicaid Lead Caseworkers will monitor the use of the template during monthly second party reviews of each caseworker. Adult Medicaid Supervisor created and utilized an Error Trends Data log effective 10/1/2024. The Error Trends Data log captures monthly errors to identify trends among staff. This log also provides Adult Medicaid leadership with data regarding errors that are repetitive to help leadership conduct monthly or quarterly refresher training as well as individualized training for staff who continue to have repetitive errors. Staff who fail to utilize the “Vehicle Status Documentation” template and continue to have repetitive errors will be placed on a corrective action plan. Policy refresher training will be held before 12/31/2024 that will cover the IV-D Referral process with specific advisory that the policy is currently suspended until further notice per DHB (Admin Letter 13-23). The Recertification Documentation template was updated on 11/20/2024 and went into effect immediately to be used by all Family and Children’s Medicaid caseworkers. The Error Trends Data log was implemented on October 1, 2024. Family and Children’s Medicaid leadership will monitor this by conducting a random selection of second party reviews each month. Section III - Federal Award Findings and Questioned Costs (continued) Kim Grissom, Income Maintenance Supervisor II; Taylor White, Income Maintenance Supervisor II; Lisa Kornegay, Income Maintenance Lead Worker III; and Sherry Stainback, Income Maintenance Lead Worker III 176

Although the Project does not currently use an interest-bearing account for project funs, 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.

Although the Project does not currently use an interest-bearing account for project funs, 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.

U.S. Department of Housing and Urban Development 2024-001 Home Investment Partnerships Program – Assistance Listing No. 14.239 Recommendation: To ensure accountability with the required reporting, we recommend management review and update the procedure to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHFA will implement electronic time tracking, this will replace the current manual process of preparing timesheets that are entered into a database used to accumulate administrative expenses charged to federal programs. This will ensure the invoices submitted for reimbursement of program administration expenses are accurate. PHFA is currently in the process of implementing a Human Capital Management system that will allow employees to track the time they work on federal programs. Name of the contact person responsible for corrective action: Adrianne Trumpy, Director of Accounting Planned completion date for corrective action plan: July 1, 2025 If there are any questions regarding this plan, please call Adrianne Trumpy at 717.780.3823.

CONDITION: During the course of the audit, auditors noted 10 of the 25 (40%) quarterly expenditure reports required by the Illinois State Board of Education were not submitted timely. Seven of the quarterly expenditure reports were submitted between 2 and 4 days late, one quarterly expenditure reports was submitted between 10 and 20 days late, and two quarterly expenditure report were submitted between 80 and 100 days late. For the federal program, auditors noted 3 of the 4 (75%) quarterly expenditure reports required by the Illinois State Board of Education were not submitted timely. One of the quarterly expenditure reports was submitted 2 days late, one of the quarterly expenditure reports was submitted 4 days late, and one of the quarterly expenditure reports was submitted 89 days late. PLAN: The Regional Office of Education #3 will submit timely expenditure reports. A system of calendar reminders as well as written procedures have been implemented. In addition, Regional Office of Education #3 has employed an additional bookkeeper to help spread the work load more evenly. ANTICIPATED DATE OF COMPLETION: Ongoing CONTACT PERSON: Ms. Julie Wollerman, Regional Superintendent

2024-004: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: The City does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. Planned Corrective Action: City was in the process of developing written policies and procedures related to federal awards during the year, but was unable to obtain board approval for the policies until April 2024. Contact person responsible for corrective action: Vicki Schroeder, Treasurer, and Eric Buckman, City Manager Anticipated Completion Date: April 2024

WHPCA has hired a third-party accountant as well as implemented additional monitoring and review and approval procedures to strengthen its financial management.

Federal Single Audit for the Period Ending June 30, 2024 Corrective Action Plan February 5, 2025 ➢ The major program the finding pertained to: 2024-001. Internal Control Over Compliance, United States Department of Agriculture, Passed-through New York State Department of Education: Child Nutrition Cluster, School Breakfast Program ALN: 10.553, National School Lunch Program ALN: 10.555 ➢ Condition: The District has not yet updated its existing policies and written procedures to conform to the Uniform Guidance requirements. ➢ Planned Corrective Action: The District has already updated its policy and related procedures in order to comply with the requirements of Uniform Guidance. The Board of Education adopted its policy in May 2024. ➢ Name, Title and Contact Info of Responsible Person: Sam M. Schneider Assistant Superintendent for Business East Hampton Union Free School District 4 Long Lane East Hampton, NY 11937 (631) 329-4106 sam.schneider@ehschools.org ➢ Anticipated Completion Date: Already implemented on May 21, 2024.

Condition: The School’s policy regarding allowable cost recognition and requests for reimbursement follow those requirements set forth by the federal program. Questionable Costs: During testing, it was determined that vision benefits had been double counted for reimbursement requests during the year ended June 30, 2024. Context: Vision benefits selected for testing had been double counted for reimbursement. Effect: The School obtained reimbursement funding over allowable amount. Cause: The School did not adequately monitor and review reimbursement submission and reporting. Identification as a Repeat Finding: Not a repeat finding Recommendation: All federal program reimbursement requests should be reviewed for accuracy and appropriateness. Response: Our management team has acknowledged the finding and has immediately implemented a review process for all federal program reimbursement submissions. The error has been fixed and the HR team has added additional controls for the calculation / review of the bi-weekly benefit deduction amounts. Contact Person Responsible for Corrective Action: Denise Alyeshmerni, Director Completion date: December 31, 2024

Condition: The School’s policy regarding allowable cost recognition and requests for reimbursement follow those requirements set forth by the federal program. Questionable Costs: During testing, it was determined that vision benefits had been double counted for reimbursement requests during the year ended June 30, 2024. Context: Vision benefits selected for testing had been double counted for reimbursement. Effect: The School obtained reimbursement funding over allowable amount. Cause: The School did not adequately monitor and review reimbursement submission and reporting. Identification as a Repeat Finding: Not a repeat finding Recommendation: All federal program reimbursement requests should be reviewed for accuracy and appropriateness. Response: Our management team has acknowledged the finding and has immediately implemented a review process for all federal program reimbursement submissions. The error has been fixed and the HR team has added additional controls for the calculation / review of the bi-weekly benefit deduction amounts. Contact Person Responsible for Corrective Action: Denise Alyeshmerni, Director Completion date: December 31, 2024

Condition: The School’s policy regarding allowable cost recognition and requests for reimbursement follow those requirements set forth by the federal program. Questionable Costs: During testing, it was determined that vision benefits had been double counted for reimbursement requests during the year ended June 30, 2024. Context: Vision benefits selected for testing had been double counted for reimbursement. Effect: The School obtained reimbursement funding over allowable amount. Cause: The School did not adequately monitor and review reimbursement submission and reporting. Identification as a Repeat Finding: Not a repeat finding Recommendation: All federal program reimbursement requests should be reviewed for accuracy and appropriateness. Response: Our management team has acknowledged the finding and has immediately implemented a review process for all federal program reimbursement submissions. The error has been fixed and the HR team has added additional controls for the calculation / review of the bi-weekly benefit deduction amounts. Contact Person Responsible for Corrective Action: Denise Alyeshmerni, Director Completion date: December 31, 2024

Supportive Housing for the Elderly (Section 202) Mortgage Financing– FAL No. 14.157 Section 202 Project Rental Assistance Contract – FAL No. 14.157 Recommendation: We recommend that management ensure any surplus cash is deposited within 90 days of year end. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will ensure future surplus cash is deposited within the required timeline. Name(s) of the contact person(s) responsible for corrective action: Tammy Neuhalfen Planned completion date for corrective action plan: January 30, 2025

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Reserve for Replacement Provisions and introduce policies and procedures to prevent oversight of incomplete or incorrect monthly deposits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the required deposit immediately. Planned completion date for corrective action plan: June 30, 2025

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. We recommend the entity make the required deposit immediately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the required deposit immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2025

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. We recommend the entity make the required deposit immediately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the required deposit immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2025

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: performing training regarding HUD requirements surrounding Allowable Cost Provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will collect improperly disbursed amounts immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2024

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Performing training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the current year required Surplus Cash deposit of $10,079 immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2024

Recommendation: Procedures should be implemented to ensure a timeline with documentation of required deposit to the Residual Receipts account based on prior year audited financial statements surplus cash calculation. We also recommend the surplus cash amount of $36,710 calculated at June 30, 2024 be deposited immediately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will implement a documented timeline to ensure proper and timely deposit of surplus cash to the residual receipts account. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2024

Repayment will be made to the SC Department of Education.