Corrective Action Plans

Statement of Condition #2023-005: At March 31, 2023, the Partnership's residual receipts account was not invested in an interest bearing account. Recommendation: The Agent should transfer the residual receipts account to an interest bearing account. Action(s) taken or planned on the finding: Agreed. The Agent concurs with the finding and the auditor's recommendation. The Partnership will transfer the residual receipts account to an interest bearing account.

16.575 - U.S. Department of Justice - Crime Victim Assistance Grant. This grant provides the salary and expenses for the Prosecuting Attorney's Victim Advocate. The County Clerk utilized the year-end expenses for the Victim Advocate grant effort which included salary, office expenses, mileage and training expenses. Our records show that a grant reimbursement of $34,583 was received for 2023. In the future, the County Clerk will ensure the total grant reimbursement amounts are utilized. 16.738 - U.S. Department of Justice - Edward Byrne Memorial Justice Assistance Grant. Our research revealed that this grant was received by our Sheriff's Office. However, the grant application and approval was not provided to the County Clerk's office. Therefore, she was unable to reflect this grant in the budget document. We have asked the Sheriff's Office to send us their grant applications so we are able to set-up a tracking system in the future. 20.205 - U.S. Department of Transportation - Highway Planning and Construction. These funds are pass-through grants from the federal government to the Missouri Department of Transportation to fund bridge replacement projects under the BRO Program. The financial audit for the fiscal year ended December 31, 2022, (finding 2022-003) cited Benton County for improperly accounting for these SEFA grants. The original SEFA amount in 2022 was $428,993 and was corrected to show $343,194. The difference was the 20% local match for these grants. The 2023 audit indicates that the County should report 100% of the grant, not just the 80% that will represent the federal/state funds. The County utilized the guidance from the 2022 to report for the 2023 projects, however, this was incorrect due the source of the funds used for matching. Benton County will ensure that 100% of the federal grants will be reflected in the financial documents moving forward for projects that are funded with soft match credit from the Missouri Department of Transportation.

For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. See § 200.302(b)(6). Except as noted in this part, the Federal agency must require recipients to use only OMB approved, government-wide information collections to request payment. The management of the Instuitution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required tme frame. Advance payment requests are done under the advance method to cover anticipated cash needs. The Federal drawdowns are requested by the Finance Office on a monthly basis and Drawdowns are based on budget forecasting and subrecipient encumbrances. All procedures for drawdowns were handled most efficiently and with proper accounting standards. However, there are instances that took more than five days to make the payments to some vendors because of invoices being received late, missing information, management resolved the issues with the vendors but the time it takes is longer than the five days. The finance department now is monitoring the upcoming expenditures and making the reimbursement request closely to the date of payments due to the vendors. Yusein Durakov (CFO) Brenda Ortiz (Business Specialist) Procedures have been implemented

The Organization has engaged a management consulting firm with expertise in financial accounting and reporting to implement additional review and oversight procedures in its financial policies.

The Organization has engaged a management consulting firm with expertise in financial accounting and reporting to implement additional review and oversight procedures in its financial policies.

Cash Management Federal Agency: U.S. Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grant Program; Federal Pell Grant Program; Federal Direct Student Loan; Federal Work Study Program Assistance Listing Number: 84.007; 84.063; 84.268; 84.033 Recommendation: We recommend management maintain proper recordkeeping and follow policies and procedures that are in effect at the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented new procedures surrounding reconciling drawdown requests and approvals. The Director of Financial Aid meets monthly with Finance and Grants Accounting to review reconciliations. Finance now submits drawdown requests to the CFO for prior‐approval and keeps them documented. Name(s) of the contact person(s) responsible for corrective action: Varah Barnett, Director of Financial Aid Planned completion date for corrective action plan: July 1, 2024

THE ORGANIZATION WILL IMPLEMENT A PROCESS TO ENHANCE INTERNAL CONTROLS ASSOCIATED WITH THE REVIEW OF REVENUES AND EXPENDITURES TIMELY TO ENSURE ACCURATE AND COMPLETE REPORTING OF THE FINANCIAL STATEMENTS. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. THE ORGANIZATION WILL USE EXPENDITURE REPORTS BY CLASS TO SUPPORT EXPENDITURES SUBMITTED FOR REIMBURSEMENT OF FEDERAL AWARD PROGRAMS. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE ORGANIZATION WILL TERMINATE THE CURRENT AGREEMENT WITH THE CPA AND MOVE TO ANOTHER CPA FIRM TO MEET THE NEEDS OF THE ORGANIZATION IN A PROFESSIONAL, QUALIFIED AND TIMELY MANNER. MOVE TO ANOTHER CPA FIRM BY NO LATER THAN SEPTEMBER 1, 2025. THE ORGANIZATION THROUGH ITS BOARD OF DIRECTORS WILL CREATE A “FINANCIAL POLICY COMMITTEE” WHICH WILL BE RESPONSIBLE TO WORK WITH THE EXECUTIVE DIRECTOR, THE NEW CPA TO OUTLINE AND CREATE NEW POLICIES, PROCEDURES AND PROCESSES, ALONG WITH OVERSIGHT OF THE FINANCIAL WELL-BEING OF THE ORGANIZATION AND REPORT TO THE BOARD OF DIRECTORS. IMMEDIATELY, THE PROCESS WILL BEGIN TO RECRUIT THE COMMITTEE MEMBERS ON JUNE 25, 2025.

Fiscal Year 2023 Single Audit Corrective Action Plan Finding Number: 2023-006 Cash Management Condition: The CMHSP has established internal controls relating to approvals of cash requests. However, during testing we noted that cash requests did not contain evidence of required approvals. Planned Corrective Action: The CFO or Finance Manager will ensure that all cash requests are approved by the proper individuals. Contact Person: Kevin Hartley, CFO 231.633.2171 Kevin.hartley@nlcmh.org Anticipated Completion Date: 10-1-24

Fiscal Year 2023 Single Audit Corrective Action Plan Finding Number: 2023-005 Reporting Condition: The CMHSP did not reconcile financial expenditures shown in the Federal Financial Report to the total disbursement and charges in PMS. Planned Corrective Action: The CFO or Finance Manager will ensure that the financial expenditures shown in the Federal Financial Report reconciles to the total disbursement and charges in PMS. Contact Person: Kevin Hartley, CFO 231.633.2171 Kevin.hartley@nlcmh.org Anticipated Completion Date: 10-1-24

1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax filings, and third-party payroll contracts. *A secure, organized system will be implemented for storing payroll-related documents, whether physical or digital. This will include utilizing secure cloud storage or an enterprise document management system with restricted access controls. *We will conduct a quarterly review to ensure that documents are being retained for the appropriate time frame and securely disposed of when no longer required. 2. Implement Stronger Controls During Payroll Provider Transitions: *We will formalize and document the process for changing third-party payroll providers. This process will include detailed steps for due diligence, transition planning, data transfer procedures, and ensuring continuous payroll processing during the transition period. *A project team will be assigned for every payroll provider change to ensure proper planning, including backup and contingency plans, data verification, and communication with both internal and external stakeholders. *A comprehensive review of the transition will be conducted after each change, including a reconciliation of payroll records to ensure that all data is accurately transferred, and all systems are functioning properly. 3. Vendor Oversight and Service Level Agreements (SLAs): *We will ensure that future contracts with third-party payroll providers include clear Service Level Agreements (SLAs) outlining the provider's responsibilities in terms of document retention, data security, and transition procedures. This will ensure that providers maintain the necessary standards and practices for managing payroll-related documents.

2023-002 Utilities Allowance Calculation – RF (2022-004) In June of 2022 new utility allowance schedules were adopted by the board, however the new schedule was not entered into the Housing Management Software. With annuals starting in November the new utility allowance schedule has been adhered.

Finding 2023-102 - Grants and contracts - Identification of expenses and reconciliation and analysis Determination - Material Weakness in Internal Controls over Compliance Responsible Party: Ervin Reed, Director of Finance Anticipated Completion Date: September 30, 2025 Planned Action: Designed a cost center structure where program direct and indirect costs are tagged. Additionally, identify all relevant funding sources for each program. Configure the accounting system (Quickbooks for FY24 and NetSuite for FY25) to use multiple segments to track both revenue and expenses - one segment for program, one segment for funding source. An 'unfunded' code will be used to capture costs not billable to specific grants.

Finding 2023-101 - Grants and Contracts - Identification of expenses and reconciliation Determination - Significant Deficiency in Internal Controls over Compliance & Allowable CostsResponsible Party: Ervin Reed, Director of Finance Anticipated Completion Date: September 30, 2025 Planned Action: Designed a cost center structure where program direct and indirect costs are tagged. Additionally, identify all relevant funding sources for each program. Configure the accounting system (Quickbooks for FY24 and NetSuite for FY25) to use multiple segments to track both revenue and expenses - one segment for program, one segment for funding source. An 'unfunded' code will be used to capture costs not billable to specific grants.

Planned Corrective Action: Review and Update: Accoutning and Personnel Policies and Procedures and update to follow OMB's Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (UG). Planned Implementation Date of Corrective Action: 07/01/2025. Person Responsible for Corrective Action: Jane Bizeur, Business Manager; Dawn Reams, Executive Director

Condition: Certain underlying support related to the VOCA Victim Assistance Formula Grant did not agree to amounts charged to the grant. Supporting information and records indicated more funds were spent by the Organization than were charged to the grant. Planned Corrective Action: Management will review its processes, procedures and controls to ensure that reconciliation and review of grant reimbursement requests and supporting underlying documentation occurs in future periods. Planned Completion Date: Ongoing Person Responsible: Kim Reed, VP of Finance

Finding #SA2023-001 Cash Management and Accuracy of Federal Financial Reports Assistance Listing Number: 20.507 Assistance Listing Title: COVID-19 – Federal Transit Formula Grants Name of Federal Agency: Department of Transportation Federal Award Identification Number: CA-2020-212-00 and CA-2022-083-00 • Name(s) of the contact person: Shay Narayan, Director of Finance • Corrective Action Plan: There was significant turn-over in the Finance Department during the periods where accounting and spending of COVID-19 related grants occurred. There was a lack of monitoring reimbursement claim activities and coordination with the Transit Division on its activities. With the Finance Department being fully staffed with competent talent, these issues should not occur in the future. • Anticipated Completion Date: 08/31/2025

Finding No.: 2023-003 Condi􀆟on: SEDOL submited grant expenditure reports for reimbursement without having sufficient support for expenditures claimed, resul􀆟ng in reimbursements greater than allowable costs. Plan: Management will implement a process to properly budget, track and monitor grant expenditures and create an improved review and oversight process. An􀆟cipated Date of Comple􀆟on: 6/30/2026 Name of Contact Person: Dr. Stephen Johns, Co-Interim Assistant Superintendent

Cash Management Planned Corrective Action: The reconciliation process will be reviewed and any deficiencies will be corrected to assure funding is drawn and disbursed within three days of receipt. Student disbursement reports will be reviewed to determine drawdown amounts before making draws from G5. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Contact Information: Sharon Hunt, Interim Chief Financial Officer, Dallam Hartley Counties Hospital District Audit Finding Reference Number: 2023-003 Planned Corrective Action: DHCHD has contracted with another payroll provider. Human Resources staff will work with the payroll provider to ensure that appropriate documentation regarding pay amounts and other essential payroll and personnel data is maintained on each employee. Anticipated Completion Date: Completed as of October 1, 2024

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update: History and Board Actions: In FY 2021, Via Hope experienced a significant loss of revenue due to the ending of contracts from its two primary funding streams – the Health and Human Services Commission and the Hogg Foundation for Mental Health. This loss of revenue resulted in the Board recommending and approving the reduction of staff and the departure of the CEO. In FY 2022, the Board recommended and approved the termination of its Accounts Manager and the former Board Chairman stepped in to voluntarily manage the finances until the organization could make other arrangements. The former chairman stepped down from his role and an election of officers was held to install a new Chair. By January 2022, with new revenue coming into the organization, the Board selected a new CEO and in December 2022, a new accounts manager was hired. Once the new accounts manager began reconciling the accounts, a pattern of questionable expenditures became evident with PayPal and other accounts. The CEO and staff informed the Board of what appeared to have happened and recognizing its fiduciary responsibility, the Board approved the engagement of a forensic audit by an external audit firm, The Wesley Peachtree Group (WPG) of Atlanta, Georgia. The forensic audit resulted in findings that fraudulent activity in the amount of $233,000 was likely to have occurred. As a result, the CEO was instructed to file an insurance claim with Frost Insurance. To process the claim, Frost required the involvement of law enforcement which was approved by the Board. Formal investigations were launched and remain ongoing with the Austin Police Department and the Travis County District Attorney's office. Recently, law enforcement met with the Board and provided an update on the investigation. Subsequently, the CEO was requested to follow up with the insurance carrier and state regulatory agencies to ensure the prompt receipt of its insurance claim from PayPal and other potential sources. II. FINDINGS AND RECOMMENDATIONS: Finding 2023-001 - Internal Control Deficiencies (Material Weakness) a) Time and Effort, Payroll and Human Resource Forms and Contracts - In response to the finding, Management will require monthly Time and Effort reports for each employee, develop new human resource forms, and update staff contracts at the beginning of the fiscal year. b) Drawdowns and Written Approvals - With the addition of the new Finance staff member in January 2025, management will initiate a written approval process. All payroll adjustments, drawdowns, credit card purchases, and payments will require invoices, receipts, and written approvals before payment is made. The Accounting Manager will also work with the CEO to ensure that staff provide receipts promptly and that journal entries are recorded on a monthly basis. c) Receipts, Written Approvals, PP&E Schedule - Receipts and written approvals were addressed in Response (C). While the organization maintains an equipment log, we will establish a formal Property, Plant, and Equipment Schedule (PP&E), particularly noting equipment purchased with federal funds. d) Segregation of Duties - Management has begun the process of interviewing qualified staff to segregate duties in the Finance office. This will ensure that one individual will no longer be responsible for handling funds, payments, reconciliations, and General Ledger (GL) postings. The individual will be in place by January 2025.

2023-011 Excess Food Service Fund Balance (Material Weakness) Management’s Response: We completed and Excess Balance Use of Funds report and worked with the State to understand exactly the parameters of this/ The funds were spent down and we are working hard to make sure to stay under the three months of expenses as worded in CFR Title 7, 210.14(b). Again management is trying to take on a bigger role as this monitoring was not considered prior to COVID. Fund Balances at year end averaged no more than $10,000. Name of Contact Person and Completion Date: Toni Butterfield Anticipated Completion Date - Immediately

Finding Number: 2023-005 Finding Title: Reporting – PR29 – CDBG Cash on Hand Quarterly and Federal Funding and Accountability and Transparency Act Program: 14.218 Community Development Block Grants/Entitlement Grants 14.218 COVID-19 – Community Development Block Grants/Entitlement Grants Name of Contact Person Responsible for Corrective Action: Max Holdhusen, Deputy Director of Community and Economic Development Corrective Action Planned: 1) Ramsey County will implement internal procedures to complete PR29 quarterly reports as required by HUD and ensure the correct accounting basis and accounts are being utilized. 2) Ramsey County will implement procedures to complete reports on FSRS required by FFATA. 3) Ramsey County will develop/update our agency’s written grants administration policies and procedures to align with current practices and applicable rules. 4) Ramsey County will conduct regular trainings of policies and procedures for staff involved with CDBG grants administration. Anticipated Completion Date: July 15, 2025

Child Nutrition – Report Testing Recommendation: We recommend that the District reviews its procedures and controls over reporting for the Child Nutrition Cluster program to ensure all reports are accurately reporting information and are reviewed by someone other than the preparer and that review is documented prior to submission of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review its procedures over its reporting of claims to MDE to ensure claims made to MDE is properly supported by the District's meals count. Name(s) of the contact person(s) responsible for corrective action: Tariro Chapinduka, Director of Business Services Planned completion date for corrective action plan: June 30, 2025

As noted in the finding, the significant staff turnover and financial constraints during the audit period caused some disruption in our ability to provide the necessary documentation for certain transactions. In light of this, we have developed and implemented a corrective action plan to ensure full compliance with 2 CFR 200, grant agreements, and cost principles going forward. 1. Strengthening Documentation Procedures: o Community Resource Center, Inc. has committed to implementing a process in which all transactions will be supported by actual invoices and all reimbursement requests will be submitted with corresponding supporting documentation. This will include both the original invoices and any other necessary backup materials. o Community Resource Center, Inc. is working with a financial consultant (start date on November 1, 2024), to audit and refine the financial systems, with particular emphasis on improving the accuracy and transparency of our documentation processes. The financial consultant will also assist in ensuring that all future costs align with the requirements of the funding agency and the OMB guidelines. 2. Review and Update of Internal Controls: o In response to the finding, Community Resource Center, Inc. has begun revising internal controls to ensure that adequate checks and balances are in place, especially in times of staff turnover. This includes designing more robust systems for tracking and documenting all costs related to grants, ensuring that all documentation is easily accessible for audit and review purposes. o A dedicated team will be assigned to monitor compliance with the internal control processes, and we will conduct regular internal reviews to verify that supporting documentation for all transactions is complete, timely, and accurate. 3. Contingency Planning for Staff Turnover: o Recognizing the impact of turnover, Community Resource Center, Inc. is formalizing a contingency plan for future staff changes. This plan will include clear guidance on the retention and transfer of all financial records, as well as designating backup staff with sufficient training and authority to oversee and maintain compliance with all financial requirements. We will also implement cross-training for key financial personnel to ensure continuity and consistency in the event of unexpected departures. 4. Ongoing Staff Training: o Community Resource Center, Inc. is committed to providing ongoing training to staff responsible for financial reporting and compliance. This will ensure that all staff involved in grant transactions understand the requirements set forth in 2 CFR 200 and other applicable regulations. Community Resource Center, Inc. will also work with the financial consultant to identify and address any skill gaps within the team. 5. Monitoring and Audit of Corrective Actions: o Community Resource Center, Inc. will establish regular internal monitoring and audits of these corrective actions to ensure they are being followed effectively. This will include periodic spot-checks of transaction documentation to ensure completeness and accuracy, as well as regular reviews of our internal controls and procedures to ensure their ongoing effectiveness.

NIYC has developed new policies and procedures around the requests for reimbursement from federal grantors. This will ensure that all requests for reimbursement are reviewed and approved before the request is submitted. It further requires sufficient supporting documentation for each request to be attached to aid in review and documentation.