Corrective Action Plans

Recommendation: We recommend that the County implement a procedure by which a monthly review of the activities billed by providers to the CLTS Third Party Administration is performed with special attention on any authorized changes in services that occurred during the month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County acknowledges the recommendation to implement a procedure for monthly review of provider-billed activities submitted to the CLTS Third Party Administration (TPA). It is our understanding that the activity subject to testing in the future for CLTS will be case management and other services directly provided by Taylor County personnel. The County will evaluate current processes to make sure they are complying. Name(s) of the contact person(s) responsible for corrective action: Tracy Hartwig, Finance Director Planned completion date for corrective action plan: December 31, 2025

Processes and controls have been implemented so that the accounting staff prepares the grant reimbursement requests which are reviewed and approved by the CEO for submission.

Processes and controls have been implemented so that the accounting staff prepares the justification and expense support of the grant reimbursement requests which are reviewed and approved by the CEO for submission.

Cash Management - TCJFS will evaluate draws every week when a draw is available to do. Draws can be done anytime during the week but must be completed by Friday at 2:00pm. TCJFS will pull in vouchers to the CFIS system from the ledger system that TCJFS anticipates being paid by the Auditor’s Office. TCJFS will then run a cost allocation with the most current RMS numbers and then use the Over/Under Report to determine the draw amount. Draws should be taken from those allocations where expenses have hit or from an allocation where we are under-drawn. TCJFS should never have more than 10 days cash on hand at the end of a quarter.

The District agrees with the finding and through education and training of staff, the District is in the process of implementing procedures to ensure that all required reports are prepared accurately and agree to the activity recorded on the District’s general ledger.

Name of auditee: MAC Housing Development Fund Corporation TIN: 014-EE134 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2024 CAP prepared by: Amanda Hamilton Finance Director Franklin County Community Housing Council, Inc. (518) 483-5934 Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Finding 2024-003 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management has deposited the underfunded amount as of the date of this report.

Finding 2024-002 – Monthly Reporting/Tracking of Government Grants Statement of Condition: MBCDC receives many cost reimbursement government grants with monthly reporting. During the audit process, MBCDC was unable to provide reports from the accounting software demonstrating the grants are fully utilized. These grants are subject to oversight and repayments could occur. Corrective Action Plan: MBCDC will update the grant tracking spreadsheets for federal funds and devote more resources to proper tracking procedures. Status: In process. Correction Action Completed For the year ended December 31, 2024, the audit disclosed no findings, questioned costs, or recommendations that were completed and required to be reported.

Condition: During the audit it was noted that there were some individuals who did not have documentation of the correct wage that was used ont he grant expenditure report. The Club also does not keep any copies of the invoices to back up which expenses are allocated to the grant. Plan: The Club plans to review the issue with its current procedures and revise them as necessary to provide better controls over grant expenditures. Anticipated Date of Completion: As soon as possible - before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have started to keep the documentation for each salary increase and review in the employee's personnel files and the supplies that have been purchased.

Condition: During the audit it was noted that, in the beginning of the year, employee timecards were missing. Plan: The Club will review their monitoring procedures to ensure consistent retention of employee timecards. Anticipated Date of Completion: As soon as possible - before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have reviewed our monitoring procedures to ensure consistent approval of employee timecards.

Condition: During the audit it was noted that instances of wages submitted for reimbursement for two Club employees were more than gross wages that should have been assigned to the grant based on the amount of the paycheck and the percentage allocation. Plan: The Club plans to review the issue with its current procedures and revise them as necessary to provide better controls over grant expenditures. Anticipated Date of Completion: As soon as possible - before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have evaluated our procedures related to grant reimbursement requests review and we are working on improving our current proceudres.

Management recognizes that there was inadequate documentation from multiple districts to support salary and benefit costs within the Title I Grants to Local Educational Agencies program. Also, Centennial BOCES recognizes, as the fiscal agent, that it is the entity responsible for compliance with the rules and regulations of the program, including for those activities taking place at each district. As a result, the Chief Financial Officer will work with the Grants Accountant that manages this program and the distribution of funds to these districts. Ultimately, corrective action will have several aspects: general training and education, targeted training and education for those districts needing more support, and follow-up with districts to ensure accountability and integrity with the rules and regulations surrounding finding # 2024- 001 cited in this single audit. The first level of corrective action will be sending resources by email to each district in our ESSA consortium. These resources will focus around the requirements of time and effort, in order to support salary and benefit costs charged to federal funds. These resources will contain informational content around time and effort requirements and citations to the Cost Principles, as well as examples and scenarios to guide districts through the proper process of documenting these costs. These emails will be to both the fiscal and program representatives at each district, and will take place in Fall 2025. Targeted support will be provided to those districts cited by the auditors as having insufficient time and effort documentation to support the salary and benefits charged to the Title I Grants to Local Educational Agencies program. In addition to the previously named elements, this will include scheduling meetings with the district fiscal representative, district program representative, CBOCES Chief Financial Officer, and CBOCES Grants Accountant. These meetings will take place either through a phone call, Zoom, or in person. In these meetings we will go over why the district documentation was deemed insufficient, and then have a conversation around the resources provided and how we can help bring the district into compliance and sustain that compliance going forward. These meetings will be scheduled during Fall 2025.As the final element of this corrective plan, CBOCES will ask districts to provide their time and effort documents that appropriately support the salary and benefits being charged during FY26. For districts with adequate documentation, we will ask for time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. For districts with inadequate documentation, we will ask for a sample of two months of time and effort documentation during the fiscal year to monitor progress. If sufficient, no further action will be required of the district. If insufficient, CBOCES will contact the district and work to remediate any inadequacies or questions. These districts will also be required to provide time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. Recognizing the timing of this single audit report, Centennial BOCES will need to address the current time and effort documentation at districts for FY25. Before training activities begin in Fall 2025, CBOCES will ask districts to provide their time and effort documents that appropriately support the salary and benefits being charged during FY25. If found to be insufficient, we will work with applicable districts to correct their documentation and prepare for training activities. This work will be tailored to the specific needs of each district. For future fiscal years beyond FY26, CBOCES will work to maintain compliance by asking each district to provide time and effort documentation at the end of the fiscal year, to support salary and benefit costs for the fiscal year. Also, new fiscal and program representatives at districts will be provided with the training and education documents named in the second paragraph of this action plan.

2024-002 Cash Management Compliance Name of Contact Person: Missy Hyman, CFO Corrective Action: Winn Community Health Center, Inc. will train staff to ensure cash management requirements are followed. This includes tracking the status of the federally funded cash disbursements against the need to draw down funds on related grants. Proposed Completion Date: March 31, 2026

Management concurs with the facts presented by the auditor. However, we do not agree with the conclusion that there is a lack of adequate internal controls in the area of program reports and accounting records. The Bank, as a Subrecipient, performs the closing of the CDBG-DR SBF grants and records each transaction in a system provided by the Recipient and its consultants. The Administrative and Performance Reports referenced by the auditor are automatically generated from the grant management systems provided by the Recipient. The differences reflected between the Bank’s records and these reports result from a system error under the exclusive control of the Recipient and its consultants. These differences were duly reported to the Recipient and its consultants for correction.

2024-006 – WATERSHED REHABILITATION PROGRAM – LACK OF CONTROLS AND IMPROPER PERIOD OF PERFORMANCE – WRD – ALN 10.916 – MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition Pembina County Water Resource District applied costs to the Watershed Rehabilitation Program after the period of performance, which shows a lack of internal controls. The total value of the expenses past the period of performance end date was approximately $170,468 which occurred through September 14, 2024, more than a month past the period of performance end date. Corrective Action Plan: We agree we will ensure costs are in the proper period of performance going forward Anticipated Completion Date: FY2025

2024-003 - IMMUNIZATION COOPERATIVE GRANT AGREEMENTS - INTERNAL CONTROLS - LACK OF SUPPORT FOR PAYROLL APPROVALS - ALN #93.268 - SIGNIFICANT DEFICIENCY FINDING TYPE: SIGNIFICANT DEFICIENCY Finding 2024-003 Federal Program: FAIN: IMMUNIZATION COOPERATIVE AGREEMENT NH23IP922623 ALN: 93.268 Year(s): 2024 Federal Agency: U.S. Department of Health and Human Services Pass Through Agency: North Dakota Department of Health Questioned Cost: $0 Condition: Upper Missouri District Health Unit does not have documented approval of the payroll transactions to ensure that the expenditures are allowable to the Immunization Cooperative Agreements program and are coded to the proper grant. Corrective Action Plan: We agree, UMDHU will be adding proper approval processes regarding payroll transactions. Anticipated Completion Date: FY 2026

1-Develop a reconciliation process for excess cash reserves to ensure compliance with loan agreements 2-Implement procedures to obtain and maintain documentation for qualifying low-income housing individuals. 3-Train staff on compliance requirements for loan agreements and reconciliation processes.

Management will deposit required amounts.

Formula Grants for Rural Area and Tribal Transit Program Federal Assistance Listing #20.509 Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdown prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will ensure there are proper segregation of duties regarding the cash drawdown process. Name(s) of the contact person(s) responsible for corrective action: Carrie Beithon, Director of Financial Services Planned completion date for corrective action plan: 12/31/2026

Management’s response/corrective action plan: Similarly, YSD acknowledges this deficiency and attributes it to a lack of knowledge of the requirements. Going forward, the School Nutrition Director will present prepared reports, prior to formal submission, to the YSD Business Administrator for supervisory review and reconciliation.

The County Clerk and Treasurer will work with the accounts payable department to update and create spreadsheets and schedule a mid-year review of SEFA funds and grants. Implementation of spreadsheets is in progress and expected to be fully implemented by June 1, 2026.

Condition: Management did not retain evidence of the execution of the Organization’s internal controls over the review and or authorization of the payment or reimbursement of credit card charges during the year. Recommendation: Management should document the review and/or authorization of credit card charges and reimbursement. Views of responsible officials: The Organization will adopt a new policy on corporate credit cards with the following general provisions. Corporate credit cards may only be issued to the Executive Director and, if approved by the Executive Director, to the heads of shelter operations, and the Organization’s Accountant. All charges shall be made solely for goods or services for the use or benefit of the Organization. Use of the credit card for the purchase of gift cards or recurring automatic transactions can only be made by the Executive Director or the Organization’s Accountant after approval by Executive Director. Receipts shall be provided to the internal accountant monthly by the 5th day of the following month. The internal accountant shall prepare a summary of all charges highlighting any 1) that are not supported by a receipt, or 2) appear questionable, and also an allocation of each charge to the appropriate expense category for financial reporting. The summary and the credit card statement shall be provided to the Executive Director for review and approval. The Executive Director will spot check actual receipt documentation for credit card2 purchases of the Organization’s Accountant and the Shelter Director. In the case of the credit card used by the Executive Director, the summary and statement shall be reviewed and approved by the Treasurer or Board President. Any improper or unsupported transaction shall create a reimbursement obligation by the card holder to the Organization. Misuse of the credit card shall be a cause for discipline in accordance with the employment manual.

The payroll procedures in place for processing payroll and paying related liabilities will be reviewed and adjusted to correct the misstatement of payroll expenses and to prevent future overpayments of liabilities. Additionally, the identified overpayments will be reimbursed to the Grantor. This will be accomplished by applying a Head Start 2025 Accounts Payable adjustment and issuing a refund check to the Office of Economic Opportunity (OEO) for the applicable programs. These corrective measures will ensure that all affected program accounts are accurately reconciled and that a zero balance is achieved for finding 2024-001.

Recommendation: CLA recommended that there is an appropriate reviewer of each claim, and expenditure reconciliation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: County will have someone other than the preparer review the report prior to submission going forward. Name(s) of the contact person(s) responsible for corrective action: Jason Jerome Planned completion date for corrective action plan: December 31, 2025

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: The Town plans to draft and adopt policies. Anticipated Completion Date: 12/31/2025 Contact: Andrew Alward, Town Administrator

Management’s Response and Corrective Action Plan: MLSC concurs with the audit finding. Management acknowledges that the previous cash disbursement policy did not fully incorporate the requirements outlined in LSC Financial Guide § 3.2.4. MLSC believes that with the implementation of the revised Cash Disbursement Policy and related staff training, all recommendations in the audit finding have been fully addressed. Responsible person: Exec. Director, Lee Pliscou and Chief Fiscal Officer, Jocelyn Mallari Corrective action planned: MLSC has reviewed and revised the policy, and the Board of Directors approved an updated Cash Disbursement policy that fully aligned with the LSC Financial Guide. MLSC staff were trained on the new procedures to ensure full understanding and compliance. The revised policy was shared with all the staff at MLSC’s share drive. Anticipated completion date: Completed