Corrective Action Plans

Finding Number 2023-213 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action 1. Implementation of Time Distribution Record (TDR) Procedures: OSDE has adopted the Time Distribution Records (TDR) procedures as outlined in the ESEA Consolidated Monitoring Toolkit and the "Time Distribution Records" presentation provided to districts on October 3, 2023 . These documents establish that all employees whose salaries are funded by federal programs must document their time and effort based on actual work performed, not budget estimates. 2. Required Documentation from Subrecipients: Going forward, LEAs will be required to submit certified time and effort records using the templates provided in the ESEA Resource Toolkit (June 2024) . These forms are designed to ensure: o Records are maintained for employees working on a single or multiple cost objectives. o Monthly or semi-annual certifications, depending on the funding structure, are completed by employees and supervisors. o Reconciliations are conducted to adjust salary allocations if actual time varies from budget estimates. 3. Training and Technical Assistance: OSDE's Office of Title Services will conduct training sessions and provide technical assistance to LEAs to ensure proper understanding and implementation of the TDR process. OSDE will also establish a central repository to track and audit submitted TDRs. 4. Monitoring and Compliance Checks: A risk-based monitoring system will be implemented to conduct periodic reviews of LEA payroll reimbursements. During desk reviews and on-site monitoring, OSDE will verify that certified time and effort records support all payroll expenditures submitted for reimbursement. 5. Policy Revision and Dissemination: OSDE will revise its federal programs procedures manual to formally include the updated TDR requirements. This policy will be shared with all LEAs and included in routine programmatic updates. These steps demonstrate OSDE’s commitment to compliance and accountability. We believe that the implementation of the certified time and effort process will provide sufficient assurance that payroll reimbursements are accurate, allowable, and appropriately allocated under Assistance Listing Number 93.323. Anticipated Completion Date 6/30/2025 Responsible Contact Person Kellie Carter, Program Manager, School Health Services

Finding Number 2023-059 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425R; 84.425U) Planned Corrective Action Beginning with FY23, the ESSER Performance Report (formerly known as the ESSER Annual Reporting) data from LEAs has been collected in our Grants Management System (GMS). This has increased the accuracy of data reported annually to USDE. Anticipated Completion Date March-2024 Responsible Contact Person Tammy Smith

Finding Number 2023-101 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action The Oklahoma Office of Management and Enterprise Services – Grants Management Office (OMES-GMO) respectfully disagrees with this finding, specifically with the criteria from the Code of Federal Regulation utilized as the sole foundation for this finding, 2 CFR §200.303. This regulation states, in part that, “The Non-Federal entity 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.” (emphasis added). For further clarity as to the standard for reasonableness, clarity can be found in 2 CFR § 200.1 Questioned cost, that states in part: Questioned cost means a cost that is questioned by the auditor because of an audit finding: … (4) where the costs incurred appear unreasonable and do not reflect the actions a prudent person would take in the circumstances. Findings bolstered by the reasonable prudent person standard in 2 CFR §200.303 must not rest on a perfect person standard, nor rest on an experienced auditor standard, but based on the care applied by the ordinary prudent person acting reasonably under the circumstances at the time of their review. From this perspective, the efforts of participants to obtain reasonable assurances included meetings, correspondence, and the gathering of documentation in support of work in furtherance of the program. If the determinations based on the documentation provided at the time satisfy reasonableness upon review, then subsequent documentation will not sustain the finding based on the criteria cited in 2 CFR §200.303. At the outset of the program, DHS was assessed as a low risk subrecipient in part due to its extensive experience with federal awards. Supporting documentation produced by the agency during the period associated with the finding reflected the breakout of the vendor’s hours and rate for the projects. Sustained communication and correspondence between the agencies and the vendor contributed to providing additional assurances that the work was consistent with the documentation in support. Agency-Specific Responses: The identified agency, DHS, provided the following independent response: OKDHS has the backup for each invoice submitted by its contractor, JGC, and reviews the invoices as the hours are reflected in the backup. OKDHS and the supplier keep detailed records and support for all activities related to CSLFRF. The Oklahoma legislation, HB 2884, effective 3/28/2023, appropriates $65 million from ARPA pandemic relief funds to OKDHS for use on 9 projects as approved by the Joint Committee on Pandemic Relief Funds. Without separating administrative costs per project, Section 13 of the bill provides that OKDHS may retain 2% of the funds appropriated in the bill for costs associated with administering the projects in the bill as a whole, "provided that no funds shall be retained that would be disallowable under the provisions of the American Rescue Plan Act of 2021". The total administrative allowance to implement HB2884 equates to $1,304,847.00. The American Rescue Plan Act of 2021 grant guidance for administrative fees at or lower than the accepted de minimis rate (10%) "does not require documentation to justify its use." Anticipated Completion Date N/A Responsible Contact Person OMES: Parker Wise DHS: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell

Finding Number 2023-108 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. OMESGMO’s internal control processes ensure subrecipient risk assessments are performed and that proper grant awarding documentation is provided to subrecipients. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-025 Subject Heading (Financial) or AL no. and program name (Federal) 20.509 - Formula Grants for Rural Areas Planned Corrective Action We concur with the auditor’s recommendations. On 06/17/2024, FSO and OMPT met to review established procedures. As of that date, the procedures are being properly followed. Anticipated Completion Date 7/1/2025 Responsible Contact Person Sam Ddamba/Eric Rose

Finding Number 2023-033 Subject Heading (Financial) or AL no. and program name (Federal) #17.225 Unemployment Insurance Planned Corrective Action OESC concurs with the audit finding and agrees with the recommendation. The decrease in the total dollars associated with this finding in comparison to the prior year demonstrates that the issue has been addressed with the programming that was completed in February 2023. The agency will continue to monitor ongoing results of the new programming to address any further adjustments needed for edge-case scenarios or to appropriately handle other system changes. Anticipated Completion Date Completed in February 2023 Responsible Contact Person Christopher O’Brien, Vice President - OESC UI

Finding Number 2023-201 Subject Heading (Financial) or AL no. and program name (Federal) 12.401: National Guard Military Operations and Maintenance Projects Program Planned Corrective Action OMD agrees with the auditors’ finding that OMD could not locate or provide the proper documentation to verify the federal cost share for maintenance personnel assigned to Appendix 1. The CFO will request an updated personnel listing from the federal Director of Engineering for state employees authorized federal reimbursement through Appendix 1 as well as the supporting documentation to validate the allowable costs for reimbursement. These source documents will be maintained in the Appendix 1 files on the Oklahoma National Guard shared portal for the required records retention period with training provided to OMD staff on where to locate the documents. Anticipated Completion Date Beginning of new fiscal year—July 1, 2025 Responsible Contact Person Angela Tackett, CFO

Finding Number 2023-038 Subject Heading (Financial) or AL no. and program name (Federal) CN CLUSTER – SCHOOL BREAKFAST PROGRAM; NATIONAL SCHOOL LUNCH PROGRAM, SPECIAL MILK PROGRAM FOR CHILDREN, FRESH FRUITS AND VEGETABLES PROGRAM AL #10.553, 10.555; 10.556; 10.559; 10.582 Planned Corrective Action Additional training of field-based staff will take place covering the areas of the SFSP review to ensure that meal counts and claim numbers are correct. A SFSP review will not be conducted prior to a claim being filed unless the SFSP program ends prior to a claim being filed. USDA guidance “encourages” a claim review to be conducted when an SFSP review is being conducted. If a sponsor operates for a month or less the review must take place while the program is operating therefore a claim would not be able to be validated. Anticipated Completion Date May 2025 (once SFSP reviews start for summer 2025) Responsible Contact Person Jennifer Weber

Finding Number: 2023-044 Finding Name: Inaccurate Information Included in the Financial Reports Finding Condition(s): The Illinois Department of Transportation (IDOT) did not prepare accurate federal financial status reports for the Airport Improvement Program. Name of Contact Person(s): • Melanie Quinn, Contracts Section Manager – Illinois Department of Transportation, Division of Aeronautics • Joe Segobiano, Bureau Chief of Administrative Services – Illinois Department of Transportation, Division of Aeronautics Corrective Action(s): IDOT is working to fully staff and train the Contracts Section of the Division of Aeronautics to ensure reporting is completed as required. Proposed Completion Date: June 30, 2026

Finding Number: 2023-028 Finding Name: Failure to Perform Cash Draws in Accordance with the Treasury-State Agreement Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not perform its cash draws in accordance with the funding technique prescribed in the Treasury-State Agreement (TSA). Name of Contact Person(s): • Lisa Clement, Audit Liaison – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Megan Buskirk, Interim Chief Accountability Officer – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Phil Keshen, Deputy Director – Illinois Department of Commerce and Economic Opportunity, Office of Financial Management Corrective Action(s): The DCEO’s Office of Financial Management (OFM) has requested that the Governor’s Office of Management & Budget (GOMB) change the funding technique for the Low-Income Home Energy Assistance Program within the Treasury-State Agreement to Pre-Issuance. This has been confirmed and will be in the agreement for fiscal year 2025. Proposed Completion Date: August 30, 2024 – Completed

Finding Number: 2023-027 Finding Name: Failure to Re-certify to the Accuracy of the Clearance Pattern Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not properly review or re-certify the accuracy of the clearance pattern specified in the Treasury-State Agreement related to cash draws for the Low-Income Home Energy Assistance Program (LIHEAP). Name of Contact Person(s): • Lisa Clement, Audit Liaison – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Megan Buskirk, Interim Chief Accountability Officer – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Phil Keshen, Deputy Director – Illinois Department of Commerce and Economic Opportunity, Office of Financial Management Corrective Action(s): The DCEO’s Office of Financial Management (OFM) has requested that the Governor’s Office of Management & Budget (GOMB) change the funding technique for the Low-Income Home Energy Assistance Program within the Treasury-State Agreement to Pre-Issuance. This has been confirmed and will be in the agreement for fiscal year 2025. Furthermore, the OFM will develop policies and procedures to comply with the appropriate funding technique. Proposed Completion Date: August 30, 2024 - Completed.

The Accountant prepares reimbursement requests and the Contracted Controller reviews and approves reimbursement before submission is submitted.

Finding 2023-042 Program Information Program Name: Low-Income Home Energy Assistance Covid-19 Low-Income Home Energy Assistance CFDA Number: 93.568 Summary of Finding Significant Deficiency in Internal Control over Compliance Agency Response The agency agrees with this finding. Corrective Action Plan DSS has strengthened internal controls to ensure all reimbursement requests are independently reviewed and approved prior to submission. Each request must now include documented evidence of review and authorization by staff who are not involved in the preparation of the request, ensuring proper segregation of duties. Supporting documentation is validated during the review process, and supervisory sign-off is required to confirm accuracy and compliance. These measures provide assurance that reimbursement requests are fully supported, independently verified, and compliant with program requirements. Contact Person(s) Responsible Brook Barlow, Chief Fiscal Services Phone: 775-684-0659 Email: mrwortman@dss.nv.gov Anticipated Completion Date Corrective Actions have been in place since July 1, 2023.

Responsible official: Edwin Garcia, Finance Director. Condition/Cause: Incomplete/late submission of required program reports for ALN 21.027 (SYEP). Corrective actions: (1) Created a Uniform Guidance compliance calendar for all reporting deadlines; (2) Implemented a pre‑submission peer review checklist (accuracy, completeness, tie‑out to ledger/SEFA); (3) Standardized reporting templates mapped to the GL; (4) Automated reminders 10 and 3 days before due dates; (5) Training provided to staff on 2 CFR 200 reporting requirements and City of Chicago contract terms. Timeline: Implemented May–June 2025; sustained monitoring through December 31, 2025. Monitoring: Monthly compliance meetings with program and finance; late submissions escalated to Executive Director.

Finding Number: 2023‐003 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: James Serbin, Chief Financial Officer Anticipated Completion Date: June 30, 2026 Planned Corrective Action: Since April 2025, Federal & State grant expenditures are verified to conform to the grant applications. Budget revisions are requested and approved before expenditures are made. After reconciling expenditures to the grant detail, timely reimbursement requests are made. Journal entries are expected to contain adequate detail and justification and Grant personnel now report to the Business Manager and Chief Financial Officer where they receive ongoing support, training and supervision. The District intends to be in compliance with 2 CFR Part 200.303 during the 2026 fiscal year.

Clean Water State Revolving Fund – ALN: 66.458 Finding: Schedule of Expenditures of Federal Awards Preparation Recommendation: Procedures should be implemented to ensure completion of an entry to the Schedule of Federal Expenditures of Federal Awards to achieve a reliable reporting of total expenditures for an audit period. Action Taken: The City of Hartwell recognizes its responsibility to prepare and present an accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with Uniform Guidance. To address this finding, the City will implement formal written procedures for the preparation and review of the SEFA.

Clean Water State Revolving Fund – ALN: 66.458 Finding: Material Weakness in Cash Management Controls Recommendation: We recommend that the City develop and implement formal, documented procedures and internal controls to ensure that federal funds are drawn only when needed and disbursed in a timely manner in accordance with federal cash management requirements. This should include documented monitoring of the timing of drawdowns and corresponding disbursements. Action Taken: The City of Hartwell acknowledges the importance of establishing formal internal controls over federal cash management activities. In response to this finding, the City will develop and implement written policies and procedures specifically addressing the timing of federal drawdowns and subsequent disbursements. These actions are expected to mitigate the risk of future noncompliance and address the material weakness identified. SIGNIFICANT DEFICIENCY None Reported

The Organization is now billing actual costs for supplies as it has done for all other expenditures. Reimbursement request procedures and all accounting functions and segregation practices will be formulated in a written document that will be in place within 120 days of completion of the audit. The Organization accepts and understands that detailed reimbursement policies and procedures should be fully developed and implemented, and actual expenditures should be billed. The Organization believes that the actual cost of supplies allocated to the project exceeded the questioned cost. The Organization will adhere to reimbursement request policies and procedures that will be documented in a written accounting manual. The Organization agrees that the reimbursement request procedures should be performed by employees with properly segregated roles and responsibilities. While the Organization did not have enough staff to segregate all accounting responsibilities, it is continually working to define and monitor segregation policies and procedures and train employees on their duties and responsibilities to ensure that reimbursement requests and all accounting functions are properly separated

Management is aware of deposit requirements and has committed the resources to ensure minimum deposit requirements are met.

Corrective Action Plan (CAP) 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, 2023 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 2023-003 (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.

The district engaged in multiple construction projects using ESSER funds. Two projects were not in compliance with the prevailing wage reporting requirements. The district has updated policy 6114 – Cost Principles – Spending Federal Funds on 6/27/2022 and 1/27/2025 to comply with the Davis-Bacon Act. In addition, the district now ensures all construction contracts are presented to and reviewed by legal counsel to ensure compliance with federal, state and local laws.

Material Audit Adjustments 1. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: Management will continue to review and gain an understanding of the audit adjustments in order to reduce the number of entries necassary for future audits. The Conuty Finance Coordinator plans to remedy this finding in future years. 3. Official Responsible for Ensuring CAP: Lisa Herges, County Administrator, is the official responsible for ensuring corrective action of the material weakness. 4. Planning Compltion Date for CAP: December 31, 2025. 5. Plan to Monitor Completion of CAP: The County Board will be monitoring this corrective action plan. Sincerely, Lisa Herges County Administrator

Corrective Action Plan: The Program will work with the finance department to better match advanced drawdowns to the actual disbursement for the period. This will be done by comparing the funds on hand (bank balance) to program costs. If sufficient funds are on hand a drawdown request will not be made. Person(s) Responsible: Deanne Bear Catches, LIHEAP Director Estimated Completion Date: Effectively immediately

Management will proceed to transfer from the operational to the reserve account $5,684 corresponding to the undeposited deficiency ($812 per month) during the period from June to December 2023. Evidence of the deposit to the reserve account will be sent to HUD office as agreed. Popular bank will be notified about the matter and while the amount is adjusted through the monthly mortgage payment, Management will continue to make monthly deposits of $812.00 through 2023 fiscal year to cover the deficiency. The responsible person for the corrective action plan is Carmen G Rivera, Blanco’s Administrative Director. The estimated completion date for the finding is May 31, 2024. Management will ensure deposits to the replacement reserve account are made on a monthly basis as stated in the use agreement.

Management will proceed to transfer from the operational to the reserve account $5,684 corresponding to the undeposited deficiency ($812 per month) during the period from June to December 2023. Evidence of the deposit to the reserve account will be sent to HUD office as agreed. Popular bank will be notified about the matter and while the amount is adjusted through the monthly mortgage payment, Management will continue to make monthly deposits of $812.00 through 2023 fiscal year to cover the deficiency. The responsible person for the corrective action plan is Carmen G Rivera, Blanco’s Administrative Director. The estimated completion date for the finding is May 31, 2024. Management will ensure deposits to the replacement reserve account are made on a monthly basis as stated in the use agreement.