Corrective Action Plans

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

2024-001 Eligibility Material Weakness/Material Noncompliance CFDA#:14.850 – Public Housing Operating Fund This finding was corrected as of June 30, 2024. Tenants were reimbursed for their excess rental payments during the fiscal year ending June 30, 2024. In addition, a policy was established to review the utility allowances for the Public Housing program every January and to review the Section 8 program every October. The Comptroller, Jennifer Yager, confirms that this new policy was in place effective June 30, 2024 and that tenants were reimbursed for the excess rental payments as of June 30, 2024. Jennifer can be reached at 203-596-2640.

1. The District has consulted with the Arkansas Division of Elementary and Secondary Education, Child Nutrition Unit (DESE, CNU) for guidance and technical assistance. 2. Per CNU guidance, the District is in the process of submitting an amended claim for October 2023 to correct the $552 discrepancy. We anticipate acceptance of this claim, resolving the issue. 3. The District has fully implemented the required CEP compliance procedures and has trained personnel to ensure future claims adhere to federal and state regulations. 4. Standard Operating Procedures (SOP) for the Child Nutrition Program have been updated to prevent recurrence of this issue. The Earle School District is committed to ensuring full compliance with all federal and state regulations regarding Child Nutrition reimbursement claims. We appreciate the guidance provided by DESE, CNU and will continue to implement measures that strengthen our oversight and accountability.

Finding 2024-004 Reporting – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan This occurrence was due to a change in management and the error was corrected when it was identified. Since then, all the documentation was submitted within parameters of the grant. Expected Completion Date 12/21/2023

Office of Administration (OA) – SSBG: The Bureau of Financial Operations (BFO) will continue conducting during-the-award subrecipient monitoring for the SSBG based on the results of the documented risk assessment. As it relates to the cash management portion of the finding, given the relatively small amount of funds involved and the number of counties affected, DHS has determined that it is not economically feasible to change the payment methodology at this time. Anticipated Completion Date: 06/30/2025 Contact Name: Kelly Graham, Director, Division of Financial Policy and Operations

Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Persons: Carmen Jodie, Principal; Patrice Henderson, Business Manager Anticipated Completion Date: June 30, 2025 Planned Corrective Action: The School previously experienced a high turnover rate in the Business Office and Administration. The School had a Principal and Acting Principals throughout School Year 2023‐ 24. The business office has obtained outside consulting services to assist in reconciliation and financial processes. The business office will continue to work with other departments in making sure they submit documentation accurately and timely. The business office will continue to work on improving the following areas: travel reimbursement, receiving reports, timely payment of bills, payment of goods, journal entries, purchase orders; per the findings listed. A Credit Card User Agreement form will be developed to support the school’s Credit Card Policies and Procedures.

Action 1: Ensure that cash drawdowns occur within a few days of disbursement as the standard of “minimizing the time elapsing between draw down of funds and disbursement for program purposes.” Action 2: Ensure that the Chief Financial Officer, Director of Accounting & Budgeting, and the HSI Grant Administrator complete the Post-Award Training available from Ed.gov. Action 3: Establish a policy that month end, quarterly, and year end balances in the HSI account are at or near $0.

Finding 2024-002: Matching Major Federal Program: Federal Transit Cluster Compliance Requirements: Allowable Costs and Cost Principles, Cash Management, Matching Response: Concur: An inaccurate reimbursement rate was applied causing overpayment of $613,075. Due to the inaccuracy of the percentage rate applied in this drawdown, Trinity Metro will actively reinforce its internal control processes to ensure detailed reviews related to cost reimbursement rates are accurately identified monthly by those who are authorized to process drawdowns. Implementation will take place immediately. Steps that will be taken include: 􀁸 Dual-Approval Process for Reimbursement Requests: Both the Grants Department and Accounting will confirm the accuracy of the reimbursement rate before submission. 􀁸 Grant Agreement Review Process: Both the Grants Department and Accounting will jointly review grant agreements before submitting reimbursement requests to ensure that the correct rate if applied. Date of Completion: This action plan will go into effect immediately. Person Responsible to Ensure Completion: Contact Person: Greg Jordan, Chief Financial Officer Contact Person: Eva Williams, Director of Budget and Grants, Finance

A.    DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner, in this case by January 10, 2025. The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t asked for the extension.

B.     In the future, we will wait until buses are on site to write checks.

C.     We do not anticipate any ESSER ARP money to be issued in the near future.

2024-002. Payroll (Improper Payments) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds COVID 19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U Condition: During the current year, the audit identified instances of duplicate salary payments being charged to Federal awards. These payments resulted in certain employees being charged to multiple grants for federal reimbursement. Our audit review revealed that payroll records including transactions where employees’ salaries were recorded more than once, leading to noncompliance with 2 CFR §200.1 regarding improper payments. Planned Corrective Action: The District acknowledges the findings and will implement stronger internal controls to ensure that salary payments are accurately recorded and reconciled to prevent duplicate submissions of reimbursement to the federal funding source. In addition, management is in the process of contacting the funding award agency to determine whether reimbursement for the improper payments charged to the grant is necessary. Responsible Contact Person: Jean Mingot Assistance Superintendent for Business Southampton Union Free School District 70 Leland Lane Southampton, New York 11968-5089 Anticipated Completion Date: June 30, 2025

Finding 2024-004 Federal Agency Name: U.S. Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Applicable Federal Award Number- Direct Loan and Guaranteed Loan Assistance Listing Number #10.766 Finding Summary: The Medical Center was not in compliance with the terms of the loan agreements related to the reservefunds. Responsible Individuals: Ron Harrington, CFO Corrective Action Plan: The CFO worked with the local bank in Concordia to establish the required reserve account equal to the 10% of the annual debt service requirement on the direct loan and the guaranteed loan for the entire year. The Hospital is now in compliance with the terms of the loan agreements related to the reserve funds as of August 31, 2024. The Hospital has access to the accounts set up at the Bank to run monthly reports and record the interest amounts to the proper GL accounts quarterly as the interest on the accounts set up at the bank accrue interest quarterly. This entry is to ensure the Gl accounts agree with the Bank statements on the Reserve funds. Anticipated Completion Date: August 2024

Management will budget and account for WIOA grant activity in the District's financial reporting system.

FINDING 2024-005 Subject: Child Nutrition Cluster –Reporting Audit Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Linda Zaborowski, CFO Contact Phone Number and Email Address: (219) 881-5536 lzaborowski@garycsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Gary Community School Corporation (GCSC) is taking immediate action to strengthen internal controls over meal count reporting. The district will fully utilize the Skyward Student Information System to track all meals, including those processed through the Point of Sale (POS) system and a la carte items, ensuring a standardized process across all schools. To improve accuracy and prevent over-claiming, GCSC is implementing a unique student ID system where each student will either scan their ID card or manually enter their assigned ID number when receiving a meal. The CFO/Food Service Director will conduct daily reconciliations of meal counts with the Food Service Management Company (FSMC) and verify all claims against source records to prevent errors. Monthly claims will be reviewed for accuracy, ensuring that second student meals and staff meals are excluded. Additionally, GCSC will establish clear policies and procedures requiring the FSMC to provide complete and accurate data for all claim submissions. Regular internal audits and staff training will be conducted to enforce compliance, and an oversight process will be implemented to detect and correct discrepancies before submission. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by March 2025.

Item 2024-003 Delinquent Claim Filings Significant Deficiency Recommendation: Filing claims should be incorporated into the month-end close process. Management Views: Management agrees with the finding. Action Planned: Claim filing has been incorporated into the month-end closing process as of November 2023. Anticipated Completion date: Complete Responsible Party: Karla Davis, Chief Financial Officer