Corrective Action Plans

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV Office of Sponsored Programs will work with PIs to ensure there is properly documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. • How compliance and performance will be measured and documented for future audit, management and performance review: Effective immediately, UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility along with applicable Deans. DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. SA – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Future progress reports will require a review from a Director or higher supervisory approval prior to submission of reports to awarding sponsor/agency. • How compliance and performance will be measured and documented for future audit, management and performance review: Preparing department will provide either a signed version and/or email approval of progress report to the NSHE System Sponsored Programs to be filed with the award in Workday. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The NSHE System Sponsored Programs Director is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

WNC – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Western Nevada College will require that all grant invoices, effective with the October 2024 billing cycle, require a level of review. The finding for 2024 was due to vacancies in the Controller’s Office and inadequate staffing. WNC has since upgraded the vacant position and posted a recruitment to help mitigate this in the future. • How compliance and performance will be measured and documented for future audit, management and performance review: All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation (such as email approval, Workday approval or hard copy signature) will be compiled for each grant invoice to provide evidence that a second level of review has been obtained. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Assigned staff will document all advance payments in the Notes section of the Award in Workday. Federal funds reimbursed in advance will be separated into an interest-bearing account. Additionally, staff will compare subrecipient expenses with advance payments on a monthly basis and follow up with the subrecipient as needed to ensure timely use of the funds. • How compliance and performance will be measured and documented for future audit, management and performance review: Staff will document advance payments in Workday's Notes section. The use of an interest-bearing account for advance funds will also be tracked. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered, including the proper application of the indirect cost rate as outlined in the grant agreement. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. WNC – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Western Nevada College will require that all grant invoices, effective with the October 2024 billing cycle, require a level of review. The finding for 2024 was due to vacancies in the Controller’s Office and inadequate staffing. WNC has since upgraded the vacant position and posted a recruitment to help mitigate this in the future. • How compliance and performance will be measured and documented for future audit, management and performance review: All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Finding 2024-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Marsha Bohannon, Controller Contact Phone Number: (317) 867-8000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The food service director will pull the End of Day Summary Reports from Lunchtime and input the information into the Child Nutrition Portal. All reports will be provided to the controller to confirm accuracy. Once reviewed and approved, the food service director will submit the report through the Child Nutrition Portal. All documents will be scanned together and be retained for audit. Anticipated Completion Date: October 2, 2024

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.

Condition - During our testing for Cash Management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson

To allocate direct cafeteria overhead costs and plan capital equipment purchases for cafeteria equipment to enhance delivery of student meals which will ensure reduction of net cash resources so as to not exceed three months of expenditures. In addition to the current mechanisms in place to utilize net cash resources, a formula was obtained and will be used to ensure the correct amount is spent. During the 23-24 school year, the district received additional covid related funding which also contributed to excess net cash resources.

Condition: During the course of the audit, it was noted that the District charged expenses to the grant that had not actually been incurred. Therefore, the reimbursement basis method was not followed and expenses that were not incurred were claimed in June 2024 resulting in the District receiving revenue before expenses were paid. Plan: The District will be sure to spend the money before claiming the expense for reimbursement. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Dr. Joel Hackney, Superintendent Management's Response: The District will be sure to spend the money before claiming the expense for reimbursement.

Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: Corrective action steps have been taken to ensure that excess cash balances are eliminated in a timely manner. The corrective action focuses on the campus-based awards, as there was only one instance of non-compliance for the FSEOG, and adds an additional step between financial aid and the finance office to verify the amount of funds disbursed to students before initiating a drawdown of funds. Anticipated Completion Date: 11/1/2024

Corrective Action Plan: The School District has begun taking action to address this issue, as follows: Equipment Improvement - School Food Service Director, Joe Kilmer, Food Service Manager, Ann Overhiser, and the School Business Administrator have plans to improve and replace cafeteria equipment. The replacement plan will be completed in conjunction with the School District’s upcoming Capital Project. This work was originally expected to be included in a prior project but due to scheduling issues, is now included in the upcoming project which is expected to be completed by August 31, 2026. Retained Balance for Pending Settlements - Wages will increase into 2025 and beyond. The minimum wage in New York State is expected to continue to rise according to legislation. The rate will rise to $15.50 per hour by the end of 2024 and to $16.00 per hour by the end of 2025. Annual increases will be published by the Commissioner of Labor and based on a number of economic factors. Due to the critical labor shortage, the School District recently increased hourly wages for food service helpers and cooks in order to attract additional workers to maintain operations. Enhanced Meals - The Food Service Director and Food Service Manager continue to take steps to improve food options. They include making improvements to center of the plate options and improving local food options as well. In addition, the School District plans to spend a portion of the School Lunch excess cash on cafeteria equipment as a part of its upcoming Capital Project which is expected to be completed by August 31, 2026. Anticipated Correction Date: August 31, 2026 Contact Information: Lisa Kuhnel Shared School Business Administrator Odessa - Montour Central School District 300 College Avenue Odessa, New York 14869

VEC will follow the bidding process stated in 2 CFR 200.320

The Board of Trustees has designated the responsibility of overseeing the accounting and financial reporting to the District’s superintendent, Jeff Byrd. See the District’s responses to this finding in the letter provided by the District on page 103. Finding 2024-002 - Significant Deficiency - Verification of Eligibility for Free or Reduced Price Meals The District has reviewed the findings and identified areas of improvement for Child Nutrition. The district will audit the Child Nutrition information after verification each year to ensure that the correct changes have been made in the software. Internal Controls will be reviewed and strengthened to ensure proper coding moving forward.

Independence Housing Authority (IHA) also received an audit finding for failing to calculate the utility allowances correctly. This was caused by previous management instructing staff to provide an appliance credit to all tenants at move-in. All staff members have been retrained in the proper procedures for calculations and allowances. All HCV program specialists have received rent calculations certifications and have been instructed to correct any prior errors immediately. The Compliance Officer is also doing random tenant file audits on a monthly basis. This should make finding

The district will add procedures to monitor that additional spending is not being done after the grant is fully spent. In addition, the District will implement controls to ensure approved budget amendments are secured prior to spending. The District will also implement controls to ensure prior year spending is considered for reimbursement requests. The District will work with the grantor agency on any necessary correction of reports and submission of supporting documentation since both grants' reimbursement requests have been fully paid for the total grant amounts.

We thought it was to be reported on the accrual basis to coincide with the Schedule of Federal Expenditures for expenditure incurred in the period of 7/1/2022-6/30/2023. If only expenses up to the amounts received were to be reported for the period, there would be no data related to the ESSER II and ARP grants to report since we had incurred expenses exceeding the cash payments received prior to 6/30/2022. The original reports were reviewed by NYSED during their desk audit and they did not report any issues with it. In the future, we will contact the agency for the reporting instruction clarifications.

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear and accurate for reporting. School sites visits, discuss counting at point of service, claiming, reimbursable meals, production records, ordering, safety and hygiene. Attend monthly zoom with School Meals Program (Dept. of Education).

The Charter School understands and acknowledges that the expenditures reported on the Education Stabilization Fund Annual Report were reported incorrectly, using the accrual basis of accounting, rather than the amount of reimbursement payments received. Creo has engaged a new partner to support and consult with on financial management and will work closely with the new partner to ensure that future Education Stabilization Fund Annual Reports are completed based on the amount of reimbursement payments received. Management will review the report and confirm the reported amounts agree to the reimbursement payments received on the NYSED Grants Finance reports via the NYSED website.

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

Item # 2024-01 Inadequate Internal controls over the recognition of revenue (Material Weakness in Internal Control over Financial Reporting) Criteria: Under U.S. Generally Accepted Accounting Standards, revenue for conditional, cost reimbursement grants is recognized when the related expenditures are incurred. Condition: Based on the results of our audit testing, we noted two material grant billings that were not recorded in the period the expenditures were incurred and were instead recorded when invoiced. Cause: Internal controls failed to detect misstatements in revenue during the year June 30, 2024. Effect: The effect of the condition was an adjustment to increase revenue (and the related by receivable) by $372,638, which was recorded in the June 30, 2024 consolidated financial statements. Auditor’s Recommendation: Management should perform a thorough analysis of revenue around fiscal year end to ensure revenue is recorded properly. Views of Responsible Officials and Planned Corrective Actions: Management understands that additional oversight and review of revenue recognition is necessary. Controls will be put into place to prevent revenue recognition issues.

The District did not familiarize itself with all the types of compliance requirements for federal grants received. In the future, the District will designate the employee responsible for each grant to become educated on all grant compliance items, and to communicate those items to all necessary parties. The Superintendent will discuss this matter with all applicable personnel on or before November 1, 2024.

Mengel, Metzger, Barr & Co. LLP (MMB) recommended management review the NYSED Grants Finance reports via the NYSED website to determine the reimbursement payments received during the applicable reporting period and agree the amounts per the website to the total amounts shown in the Education Stabilization Fund Annual Reporting. Corrective Action: – Management will ensure that the reporting method utilized for any further Annual Education Stabilization ESSER Fund reports will be completed on a cash basis. Anticipated Completion Date: The corrective action will be implemented by February 2025 Person responsible for implementation: Anne Culver, Finance & HR Manager

Condition: During our review of Food Service funds, we noted that the numbers of meals served was less than the amount that was submitted for reimbursement. Criteria: When a recipient of federal food service money goes to submit for reimbursement, the amount of meals that are served should match up with the reporting out of the recipients system to ensure proper reimbursement is taking place. Cause: The Food service department did not have a proper reconciliation practices to ensure accurate reporting Effect: Funds may be overdrawn. Perspective: The majority of the buildings were accurate as we found during testing, with high turnover in the space training may not have taken place. Recommendation: We recommend training of all food service recording staff as well as the Director of Food service understand that the reimbursement of meals report should match the meals served reporting that documents each day of the meals served. It should also be noted that the meals served documents needs to have oversight to ensure those reports are accurate on a daily basis. Views of Responsible Officials and Planned Corrective Actions: Haven USD 312 staff involved are undergoing training to learn requirements. Processes and procedures are being developed to ensure proper record keeping and reporting.

Finding Reference Number: 84.425U ARP ESSER Description of Finding: Vertus Charter School was required to submit the Education Stabilization Fund Annual Reporting to New York State Education Department. It was found that Vertus Charter completed the reporting based on cash expenditures made during the required period of July 1, 2022, to June 30, 2023, and not based on the cash expenditures related to cash received during the stated required reporting period. Statement of Concurrence or Nonconcurrence: Vertus Charter School agrees with the audit finding. Corrective Action: Immediate Actions Taken: 1. Upon identification of the issue, the organization immediately reviewed the instructions to complete the Education Stabilization Fund Annual Reporting and compared it to the report submitted to identify the discrepancy. 2. The organization will determine appropriate steps to correct the report and/or other actions based on guidance provided by New York State Education Department. Root Cause Analysis: The reporting error occurred because there was a misinterpretation of the reporting methodology required to file the ESF Annual Report. Instead, the organization used the reporting methodology required to file the Annual ESSA Financial Transparency Report – Charter School Actual Expenditures, whereby the actual cash expenditures made during the reporting period are reported, vs. reporting expenditures made using the cash received under the program during the reporting period. Planned Actions to Prevent Recurrence: 1. Training for Staff: a. All staff responsible for preparing and submitting financial reports will undergo mandatory training on federal reporting requirements. Responsible Party: Outsourced Chief Financial Officer Timeline: Complete by January 15, 2025 2. Revised Reporting Procedures: a. The organization will ensure that information reported in the ESF Annual Report is based on the correct accounting methodology in accordance with instructions from the New York State Education Department and the U.S. Department of Education requirements. Responsible Party: Outsourced Chief Financial Officer Timeline: Effective immediately Name of Contact Person: Julie Locey, Chief Education Officer, 585-747-8911. jlocey@vertusschool.org Projected Completion Date: All corrective actions will be completed by February 15, 2025. If there are any questions regarding this Plan, please call me at 585-747-8911.