Corrective Action Plans

We agree with the finding and recommendation. We will implement procedures to ensure that future reporting of expenditures on this required report is accurate.

Finding Number: 2024-002 Finding Synopsis: The District submitted a claim for meals higher than the count actually served for the month due to a clerical error. The District did not have someone, other than the preparer of the monthly claim, review the claim before it was submitted to ensure its accuracy. Action Steps: Management plans to implement a review process to ensure the claim forms are filled out correctly. Contact Person: Jeffrey Schubert Chief School Business Official 779-244-1000 Anticipated Completion Date: 6/30/2025

In Finding 2024-003, a condition was noted in which the Organization made three draws of federal funds that were not disbursed in a timely manner for program expenditures. The Organization understands the requirements to disburse federal funds in a timely manner. In response to Finding 2024-003, procedures will be established to minimize the time elapsing between the transfer of funds to the Organization from the U.S. Treasury and the issuance of payments for program purposes by the Organization.

Finding No.: 2024-001 - Significant Deficiency Personnel Responsible for Corrective Action: Teri Gregory, CFO of Good Shepherd Children and Family Services Anticipated Completion Date: March 31, 2025 Corrective Action Plan: Good Shepherd Children and Family Services (GS) will implement a control procedure to ensure proper review of monthly financial reimbursement reports for accuracy. An Archdiocese Finance Office accountant will prepare the monthly reports. Reports and supporting documents will be sent to GS's Chief Program Officer and Pregnancy & Parenting Services Program Director. GS management will review and approve the reports before submitting them via email, along with approvals for reimbursement.

Corrective Action: Comment: Because our fiscal year ends on the month of February, we didn’t supply data to our financial auditors until August into September. Because our auditors were behind in their commitments, it pushed back our final audit by a couple of months. • First, we changed auditing firms. o We needed a firm that could commit to having financials completed in a timelier manner. • Most of our information had to be supplied to the auditors in the 3rd month after fiscal year end. • Sampling and testing need to begin as soon as data is received from BTAMC.

Finding 2024-004 - Material Weakness and Material Noncompliance: Eligibility and Reimbursement Request for Child and Adult Care Food Program Corrective Action: The District will collaborate with MDE Nutrition staff to complete training, staff assistance visits, and previously established corrective actions. The Business Director and Food Service Director will schedule additional training and visits with Nutrition liaisons and MDE PAL partners. The District will implement electronic point-of-sale devices and digital filing systems to improve recordkeeping and sharing. Documented training for YCS Food Service Staff will be ongoing. District monitoring will be reinstated to ensure compliance with pre-COVID standards. Responsible Person: Director of Finance and Food Service Director

1. The School will establish a grant management calendar to track all grant-related deadlines, including submission dates for final expenditure report. 2. The School’s management will conduct quarterly review of the grant expenditures and budget alignments for the major government grants.

Management plans to implement procedures for grant funded expenditures to ensure that proper documentation supporting the funds request are available and at the time the drawdown of grant funds.

Student Financial Assistance Cluster- Assistance Listing No. 84.268 Finding: The College did not have documentation that Direct Loan Reconciliation was performed. Context: During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause: Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely. Recommendation: We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A formal review process was already in place. The issue came from the turnover in the FA department leading to a loss of access. This will be remediated moving forward with more than one FA staff having reporting access and knowledge of reconciliations. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Management is in the process of improving controls to ensure that all approved residual receipt recaptures requested by HUD are timely remitted to HUD. Contact person responsible for corrective action: Fikru Nigusse, CFO Anticipated Completion Date: June 30, 2025

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.