Corrective Action Plans

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.

Daily meal county reports will be reviewed and verified that it agrees to the edit check worksheets prior to monthly reimbursement submission. Any differences will be properly investigated and resolved.

Corrective Action Plan: The District will implement appropriate internal controls over grant claims in order to ensure that amounts claimed for reimbursement are appropriate and match documentation. Anticipated Corrective Action Plan Completion Date: 6/30/2025 Contact Information: For additional information regarding this finding, please contact Patti Hoppus, District Bookkeeper at 262-835-2929

Corrective Action Plan: The District will monitor expenditures related to Federal grants in order to appropriately record these expenditures. The District will compare recorded expenditures to grant claims prior to claim submission to ensure that the claims match the accounting records. Anticipated Corrective Action Plan Completion Date: 6/30/2025 Contact Information: For additional information regarding this finding, please contact Patti Hoppus, District Bookkeeper at 262-835-2929.

Management agrees with the finding and is in the process of revising internal controls to address this issue.

Action Taken: The district concurs with this finding. The district has already addressed and taken action on this item. The 90K fiscal action from TDA was agreed upon. Sodexo reimbursed $45K by applying credit on the food service cost invoice. The administrative assistant to the CFO has been trained on TDA Basic Claims process and prepares the claim monthly using reports from Systems Design. Going forward The Deputy Superintendent will provide oversight on the food service management company and the claims processing.

Finding 2024-001: Student Financial Aid Cluster Cash Management View of Responsible Officials and Planned Corrective Action: The College has documented procedures in place - Prior to drawing funds from the DOE, Student Accounts and Financial Aid will review the amount showing available on COD and the disbursement amount that was made to students for the first draw of the AY, and then from each draw to the next for the remaining draws for an academic year. The amount drawn will be determined by the posted amounts to students' accounts. After COD is updated with the drawn funds Student Accounts and Financial Aid will again review to see if any excessive funds were drawn, and will return these funds to the DOE within seven days.

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2024-003 Statement of Condition: Management made an unauthorized withdrawal of $4,400 from the residual receipts account during the fiscal year ended June 30, 2022; the funds have not been returned to the residual receipts account. Auditor Recommendation: Management should deposit $4,400 into the residual receipts account to refund the unapproved withdrawals. Management should also contact the HUD Project Manager to develop a plan to get current with vendors and fund the residual receipts account. A rent increase may be necessary. S3800-130: Response Indicator: Agree. S3800-140: Completion Date: February 3, 2025 S3800-150: Action Taken: The board had decided to change property management firms because of the history and severity of financial statement findings and major program fundings prior to the discovery of the unrecorded expenses. The board believes that the new management firm has a properly designed and functioning system of internal controls to prevent such future occurrences. As a result of the discovered unpaid invoices discussed in Finding 2024-001, property management will be unable to make the required residual receipts reserve deposit and pay all vendors without a rent increase from HUD. Management plans to contact the HUD Project Manager to develop a plan to get current with vendors and fund the residual receipts account. A rent increase may be necessary.

Finding (Condition): The supporting documentation for expenses that the School DIstrict incurred did not agree to amounts requested for reimbursement. Recommendation: That applications for reimbursement are reviewed to ensure that supporting documentation agrees to amounts requested for reimbursement. Method of Implementation: Review and enhance internal controls, including report analysis prior to NJDOE Submission. Person Responsible for Implementation: School Business Administrator & Director of Special Education Implementation Date : 02/01/2025

From the desk of Rev. Vickie Keys, Executive Director. Date: January 20, 2025. Re: Lost Monitoring Visit form - Audit Finding Reference: 2024-001. The following corrective action plan will be implemented February 1, 2025 to ensure monitoring view forms are not misplaced. Step 1: The Director of Operation will make monitoring visit assignments for the month. Step 2: Each Compliance Officer is to submit the monitoring form to the Director of Operation no later than the last day of the month the visit was due to be performed. Step 3: The Director of Operation will follow up with each Compliance Officer to ensure forms were received, review the form, and enter the date the visit was completed into the data base to ensure visits are made as TDA requires. Step 4: The Executive Director will review the final report of all visits conducted for the month to sensure forms are accounted for. Step 5: The Director of Operation and the Office Clerk will perform random binder checks to see if forms are filed correctly. Step 6: The Director of Operation will oversee the labiling and thinning process of forms and binders before sending boxes to storage. This will ensure stored files can be easily located. The Executive Director has final responsibility for the implementation and maintenance of this procedure.

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 - Education Stabilization Fund: ARP Homeless II (Assistance Listing# 84.425U) ARP Leaming Loss (Assistance Listing# 84.425U) ESSER II (Assistance Listing# 84.425D) ARP Summer Enrichment (Assistance Listing# 84.425U) ARP Comprehensive After School (Assistance Listing# 84.425U) ARP ESSER III (Assistance Listing# 84.425U) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria - Expenditures must be used to prevent, prepare for, and respond to COVID-19. These programs are authorized, as applicable, by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, 2021, Pub. L. No. 116-260 (December 27, 2020), and the American Rescue Plan (ARP) Act of 2021, Pub. L. No. 117-2 (March 11, 2021). The regulations in 34 CRF Part 76 (State Administration), 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Award and 31 CFR Part 205 (Cash Management Improvement Act) apply to these programs. The School District must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. ( d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local and tribal laws regarding privacy and responsibility over confidentiality. Condition/Context - We haphazardly sampled five COVID-19 - Education Stabilization Fund (ESF) expenditures. Our audit procedures found one disbursement where management overrode documented internal control procedures. We viewed invoices, purchase orders, and payment support and noted the disbursement was processed and paid without proper documentation to support the payment made and the payment was processed without the internal claims auditor's review prior to payment. Cause - Management override of established controls. Effect - Revenues and expenditures for one of the ESF grants were overstated prior to adjustment. Adjustment resulted in recording a receivable from the vendor and an offsetting liability to the passthrough agency providing the grant funding. Questioned Costs - None. The improper payment was subsequently adjusted out of expenditures. Recommendation - We recommend that the School District ensures that only disbursements that have been processed and approved by the internal claims auditor to be paid. Management Response - School District management concurs with the finding and will take corrective action. Corrective Action - The Business Office will review and adhere to all cash disbursements procedures and protocols. Completion Date - Effective immediately. Respectfully Submitted, Dr. Brett Miller, Assistant Supt. for Business

1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management concurs that it failed to make required deposits into the Residual Receipt account in the amount of $12,574 for the year ended June 30, 2023, and acknowledges that there was no HUD approval for non-payment. b. Action(s) Taken or Planned on the Finding Management has initiated a transfer of funds into the Residual Receipt account as of 9/23/2024. The General Partner has also assigned a permanent Asset Manager to ensure required payments are made in accordance with agreements.

1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management concurs that the Project withdrew from the residual receipts reserve in the amount of $8,409 without HUD approval. Management is in agreement with the recommendation to deposit $8,409 into the residual receipts reserve. b. Action(s) Taken or Planned on the Finding Management has made changes to internal controls to prevent and detect unauthorized withdrawals from reserves. Management further notes that they have re-trained staff, and reaffirmed the review and approval process to ensure required residual receipt reserve withdrawals are completed with proper HUD authorization. Management will complete the required reimbursement to the residual receipts reserve by October 31, 2024.

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-004 Inaccurate Resources Entry Name of contact person: Sabrina Magedanz, Medicaid Program Manager Corrective Action: Proposed completion date: 10/17/2024 Finding 2024-005 Inadequate Request for Information Name of contact person: Sabrina Magedanz, Medicaid Program Manager Corrective Action: Proposed completion date: 10/09/2024 and 10/17/2024 Finding 2024-006 Untimely Review of SSI Terminations Name of contact person: Sabrina Magedanz, Medicaid Program Manager Corrective Action: Proposed completion date: 10/17/2024 Section III - Federal Award Findings and Questioned Costs (continued) Training has been conducted on the Inaccurate Resource topic with staff specifically concerning the finding areas and ensuring all verified resources are appropriately updated in the NC FAST evidence. Second party reviews will be enhanced to ensure those conducting the review ensure that proper procedures are being followed with regard to these policies. Training has been conducted on the Inadequate Request for Information topic with staff specifically concerning the finding areas and ensuring all required requests for information are sent via 5097/20020 where applicable. Second party reviews will be enhanced to ensure those conducting the review ensure that proper procedures are being followed with regard to these policies. Training has been conducted on the Untimely Review of SSI Terminations topic with staff specifically concerning the finding areas and ensuring all timeframes are adhered to when processing actions. Second party reviews will be enhanced to ensure those conducting the review ensure that proper procedures are being followed with regard to these policies. 170

Projects of Regional and National Significance – Assistance Listing No. 93.243 Recommendation: We recommend the Organization document review of all billings Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has recently hired a Chief Financial Officer (CFO), which will provide an additional layer of financial approval and review. Finance Director will complete billings and CFO will review for accuracy each month, which will provide for additional oversight. Name(s) of the contact person(s) responsible for corrective action: Jennifer Steines and Angie Meiers Planned completion date for corrective action plan: February 2025

UWGC does not have specific policies and procedures in place as to how monthly personnel costs across federal programs will be aggregated and charged and reported to federal programs. Management’s Corrective Action Plan: UWGC has developed a procedure as outlined below in “Payroll Allocation Grants” to ensure that prior to submission of invoices to federal awarding agencies, management prepares a monthly analysis based on 211 call logs to support the actual amounts allocated across all programs and invoiced to the awarding agencies that are reconciled to payroll reports, which then will allow UWGC to present evidence that all hours submitted for reimbursement are supported with the appropriate allocation. The process will include management staff from both 211 and finance departments thus maintaining internal controls. Additionally, this procedure will be reviewed at least annually by both departments as it relates to the allocation methodology to ensure that its appropriate given changes in the program and workforce.