Corrective Action Plans

We thought it was to be reported on the accrual basis to coincide with the Schedule of Federal Expenditures for expenditure incurred in the period of 7/1/2022-6/30/2023. If only expenses up to the amounts received were to be reported for the period, there would be no data related to the ESSER II and ARP grants to report since we had incurred expenses exceeding the cash payments received prior to 6/30/2022. The original reports were reviewed by NYSED during their desk audit and they did not report any issues with it. In the future, we will contact the agency for the reporting instruction clarifications.

The District Corrective Action Plan is to follow the corrective action plan set forth in the site review by the State of Alaska Child Nutrition Program to have intense staff meetings with cooks and meal counters to make sure point of service meal counts in the cafeteria or in the classroom are clear and accurate for reporting. School sites visits, discuss counting at point of service, claiming, reimbursable meals, production records, ordering, safety and hygiene. Attend monthly zoom with School Meals Program (Dept. of Education).

The Charter School understands and acknowledges that the expenditures reported on the Education Stabilization Fund Annual Report were reported incorrectly, using the accrual basis of accounting, rather than the amount of reimbursement payments received. Creo has engaged a new partner to support and consult with on financial management and will work closely with the new partner to ensure that future Education Stabilization Fund Annual Reports are completed based on the amount of reimbursement payments received. Management will review the report and confirm the reported amounts agree to the reimbursement payments received on the NYSED Grants Finance reports via the NYSED website.

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

Management Response The Charter School will review the NYSED Grants Finance reports via the NYSED website for the July 2022 – June 2023 reporting period to determine actual payments received and total amounts shown in the Education Stabilization Fund Annual Reporting on a cash basis. This will ensure that the information is shown in accordance with the instructions for the NYSED report and related US DOE requirements. The school will proactively reach out to NYSED to inform them of any variances and will update reporting should NYSED re-open the Education Stabilization Fund Annual Reporting. Additionally, the Charter School will adhere to reporting requirements for the 2023-24 Education Stabilization Fund Annual Reporting and implement a new internal control allowing for multiple and secondary reviews of federal grant reporting requirements prior to submission, in an attempt to identify inaccuracies proactively.

Item # 2024-01 Inadequate Internal controls over the recognition of revenue (Material Weakness in Internal Control over Financial Reporting) Criteria: Under U.S. Generally Accepted Accounting Standards, revenue for conditional, cost reimbursement grants is recognized when the related expenditures are incurred. Condition: Based on the results of our audit testing, we noted two material grant billings that were not recorded in the period the expenditures were incurred and were instead recorded when invoiced. Cause: Internal controls failed to detect misstatements in revenue during the year June 30, 2024. Effect: The effect of the condition was an adjustment to increase revenue (and the related by receivable) by $372,638, which was recorded in the June 30, 2024 consolidated financial statements. Auditor’s Recommendation: Management should perform a thorough analysis of revenue around fiscal year end to ensure revenue is recorded properly. Views of Responsible Officials and Planned Corrective Actions: Management understands that additional oversight and review of revenue recognition is necessary. Controls will be put into place to prevent revenue recognition issues.

The District did not familiarize itself with all the types of compliance requirements for federal grants received. In the future, the District will designate the employee responsible for each grant to become educated on all grant compliance items, and to communicate those items to all necessary parties. The Superintendent will discuss this matter with all applicable personnel on or before November 1, 2024.

Mengel, Metzger, Barr & Co. LLP (MMB) recommended management review the NYSED Grants Finance reports via the NYSED website to determine the reimbursement payments received during the applicable reporting period and agree the amounts per the website to the total amounts shown in the Education Stabilization Fund Annual Reporting. Corrective Action: – Management will ensure that the reporting method utilized for any further Annual Education Stabilization ESSER Fund reports will be completed on a cash basis. Anticipated Completion Date: The corrective action will be implemented by February 2025 Person responsible for implementation: Anne Culver, Finance & HR Manager

Condition: During our review of Food Service funds, we noted that the numbers of meals served was less than the amount that was submitted for reimbursement. Criteria: When a recipient of federal food service money goes to submit for reimbursement, the amount of meals that are served should match up with the reporting out of the recipients system to ensure proper reimbursement is taking place. Cause: The Food service department did not have a proper reconciliation practices to ensure accurate reporting Effect: Funds may be overdrawn. Perspective: The majority of the buildings were accurate as we found during testing, with high turnover in the space training may not have taken place. Recommendation: We recommend training of all food service recording staff as well as the Director of Food service understand that the reimbursement of meals report should match the meals served reporting that documents each day of the meals served. It should also be noted that the meals served documents needs to have oversight to ensure those reports are accurate on a daily basis. Views of Responsible Officials and Planned Corrective Actions: Haven USD 312 staff involved are undergoing training to learn requirements. Processes and procedures are being developed to ensure proper record keeping and reporting.

Finding Reference Number: 84.425U ARP ESSER Description of Finding: Vertus Charter School was required to submit the Education Stabilization Fund Annual Reporting to New York State Education Department. It was found that Vertus Charter completed the reporting based on cash expenditures made during the required period of July 1, 2022, to June 30, 2023, and not based on the cash expenditures related to cash received during the stated required reporting period. Statement of Concurrence or Nonconcurrence: Vertus Charter School agrees with the audit finding. Corrective Action: Immediate Actions Taken: 1. Upon identification of the issue, the organization immediately reviewed the instructions to complete the Education Stabilization Fund Annual Reporting and compared it to the report submitted to identify the discrepancy. 2. The organization will determine appropriate steps to correct the report and/or other actions based on guidance provided by New York State Education Department. Root Cause Analysis: The reporting error occurred because there was a misinterpretation of the reporting methodology required to file the ESF Annual Report. Instead, the organization used the reporting methodology required to file the Annual ESSA Financial Transparency Report – Charter School Actual Expenditures, whereby the actual cash expenditures made during the reporting period are reported, vs. reporting expenditures made using the cash received under the program during the reporting period. Planned Actions to Prevent Recurrence: 1. Training for Staff: a. All staff responsible for preparing and submitting financial reports will undergo mandatory training on federal reporting requirements. Responsible Party: Outsourced Chief Financial Officer Timeline: Complete by January 15, 2025 2. Revised Reporting Procedures: a. The organization will ensure that information reported in the ESF Annual Report is based on the correct accounting methodology in accordance with instructions from the New York State Education Department and the U.S. Department of Education requirements. Responsible Party: Outsourced Chief Financial Officer Timeline: Effective immediately Name of Contact Person: Julie Locey, Chief Education Officer, 585-747-8911. jlocey@vertusschool.org Projected Completion Date: All corrective actions will be completed by February 15, 2025. If there are any questions regarding this Plan, please call me at 585-747-8911.

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD hired an experienced and independent contract grants specialist. She is using Outlook to set up reporting reminders to ensure timely submission of reports. In addition, the Business office started using a calendar developed by ALASBO which addresses all reporting requirements for the school districts in Alaska. Proposed Completion Date: Implemented January 1, 2024

Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton , Director of Grant Accounting. Planned completion date for corrective action plan: Implemented for FY25

CORRECTIVE ACTION PLAN October 21, 2024 Berkeley County Public Service Water District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, VA 2280l Audit period: June 30, 2024 The findings from the June 30, 2024 Schedule of Findings and Questioned Costs (the "Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS- FINANCIAL STATEMENT AUDIT 2024-001: Material Audit Adjustments (Material Weakness) Condition: During the audit, we detected material misstatements in the trial balance. Generally accepted auditing standards dictate that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Recommendation: Material audit adjustments indicate that financial information presented to us for the audit was missing or inaccurate. We recommend that management implement processes to ensure accuracy of a accounts. Additionally, all adjustments that were made as a result of our current year audit should be reviewed during the next year as a reminder of matters needing accounting attention in preparing for the 2025 audit. Corrective Action: The District uses outside parties to oversee grant management and lease calculations, both items that required material adjustments. District management will review work performed by outside parties to ensure completeness and accuracy. FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-002: Single Audit Performance -Assistance Listing #66.468 and Reporting Condition: A single audit was not performed for a major program for the fiscal year ended June 30, 2023. Criteria: A single audit in accordance with the requirements set forth in the Uniform Guidance is required if total federal expenditures exceed $750,000 in a fiscal year. Federal expenditures exceeded $750,000 and the major program was a high-risk Type A program for the year ended June 30, 2023. Cause: The program required revolving loan fund drawdowns, which did not occur within the fiscal year funds were expended. Effect: The identified Type A high risk program was not tested as major. Questioned Costs: N/A Recommendation: Ensure management considers federal award compliance requirement and ensures that such requirements are satisfied each year. Corrective Action: Management will monitor major programs and ensure that they are tested when necessary. The grant in question was tested during 2024. 2024-003: Controls Over Cutoff - COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing #21.027 and Compliance- Material Weakness Condition: During our review of CSLFRF expenditures, we noted approximately $2,577,622 of allowable costs that were recorded in the wrong period. Criteria: The expenditures must be reported in the proper period for accurate reporting on the Schedule of Expenditures of Federal Awards. Cause: Procedures in place to ensure all expenditures are recorded in the proper period were not followed. Effect: Approximately $2,577,622 of allowable costs were recorded in fiscal year 2025 instead of fiscal year 2024. Questioned Costs: N/ A - the expenditures in question are allowable costs that were reported in the wrong fiscal year. Perspective Information: Five invoices were recorded in the wrong fiscal year. Recommendation: We recommend continued communications with all individuals involved in the grant process to ensure activity is recorded in the proper reporting period. Corrective Action: The District uses an outside party to oversee grant management. District management will review work performed by outside parties to ensure completeness and accuracy. If the Federal Audit Clearinghouse has questions regarding this plan, please call Jim Ouellet, Executive Director, at 304 262 3371.

CORRECTIVE ACTION PLAN November 13, 2024 Frontier Health respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 636 Shelby Street, Suite 400 Bristol, TN 37620 Audit period: June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-001: Opioid State Targeted Response - AL# 93.788, Unallowable Costs Condition: Food and beverage items were charged to the grant that were unallowable. Criteria: Only allowable costs should be charged to the grant. Cause: Procedures in place to ensure that only allowable expenditures were charged were not followed. Effect: The food and beverage items are subject to disallowance. Questioned Costs: NIA Perspective Information: One out of twenty-five items tested contained unallowable items. The amount of the unallowable costs was $59 out of a total of $7,912 dollars tested. Repeat Finding: No Recommendation: Frontier Health should review all grant agreements and approved budgets to ensure only allowable items are being charged to the grant. Corrective Action: Frontier Health will request that in future contracts they be allowed to charge food/beverage expenses for meetings since they are legitimate expenses. This was corrected in September 2024. We reached out to the state rep and due to the small amount of the item we were advised to make an adjustment to back off this amount from food and beverage expense and charge it to a covered expense. This grant runs from October 1st to Sept 30th each year. 2024-002: Substance Abuse and Mental Health Services -AL# 93.243, Overcharged Grant Condition: The Impact August 2023 expenditures were overcharged to the grant. Criteria: Only allowable costs should be charged to the grant. Cause: Procedures in place to ensure that only the correct amount of expenditures were charged were not followed. Effect: The overcharged amount is subject to disallowance. Questioned Costs: NI A Perspective Information: One month out of eleven months where expenditures were tested contained an overcharge of amounts to the grant. Repeat Finding: No Recommendation: Frontier Health should review all grant expenditure documents to ensure the correct amount of expenditures are being charged to the grant. Corrective Action: Frontier Health has issued a check back to the grantor for the overcharged amount and will ensure only the correct amounts are submitted for reimbursement in the future. If the Federal Audit Clearinghouse has questions regarding this plan, please call Allen Harris, CFO, at 423-467- 3723. Sincerely yours, Allen Harris Chief Financial Officer

Finding #2024-003 Management acknowledges that the reporting method utilized for the Annual Education Stabilization ESSER Fund report should have been completed on a cash basis which is based on reimbursement of expenses received during the fiscal year. Classical Charter Schools will take the necessary steps to comply with the cash basis reporting method on all future Annual Education Stabilization ESSER Funds reports. The Grants Manager will review the instructions for completing the Annual Education Stabilization ESSER Fund when it is open in the portal (normally in January). Name of Contact Person: Dr. Vivian Cassaberry-Furby, Director of Business vfurby@classicalcharterschools.org

City Staff incorrectly thought that all projects noted in the Action Plan submitted to HUD were covered under the Release of Funds (ROF). As the environmental review had not been fully completed at the time the project was submitted in the Action Plan, a separate ROF was needed. The necessary steps have been taken to correct the documentation and to prevent future occurrences.

Management’s Response: Although a formal approval/sign off was not done with each monthly submission of invoices to the Department of Education from July through November, accounting personnel worked closely with management regularly during this process. Particular services being submitted by community mental health centers that did not appear to fall within the guidelines of the grant focus were discussed and declined from submission if appropriate. Regular monthly reporting on expenditures from each CMHC and the overall draw down was also provided by accounting personnel to management. The recommendation for formal approval/sign off by management after accounting personnel has prepared the invoice for the DOE has been implemented. The Organization did implement a process for review after recommendations made by the auditor as part of their engagement as of and for the year ended June 30, 2023.

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. For certain periods during the year the School District asserts there was a review process in place over the reimbursement requests; however, the review was not documented, and therefore we were not able to verify if the control was in place and operating effectively. For other periods during the year, the School District did not have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Ultimately, the lack of a review control during the 2023-2024 fiscal year did not result in inaccurate reporting or incorrect amount of reimbursement paid by the Michigan Department of Education. The Business Office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: Kevin Taratuta, Chief Financial and Operations Officer Anticipated Completion Date: August 1, 2024

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame. Corrective Action Plan: This is the first time, to the University’s knowledge, that this error has occurred. We believe it was a one-off employee manual oversight, and not a systemic issue. We believe the general procedures for performing the Title IV drawdowns are in good standing; however, we will add a process where the AVP of Business and Finance regularly reviews the Title IV drawdowns to prevent this in the future. Anticipated Completion Date: 12/31/2024

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition The University did not return credit balances to students within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. Anticipated Completion Date: 11/30/2024

The project had insufficient cash to make the required deposit. Management is in consultation with the HUD representative for an acceptable solution with anticipated resolution by October 31, 2024.

The project had insufficient cash to make the required deposit. Management is in consultation with the HUD representative for an acceptable solution.

The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of the University of Oklahoma. 2024-001 Student Financial Assistance Cluster, ALN 84.063 Federal Pell Grant Program and ALN 84.268 Federal Direct Student Loans, Department of Education, Award Year 2024 Criteria or Specific Requirement - Cash Management, 34 CFR 668.162(b)(3) Finding Summary: For institutions on the Advance Payment Method, Title IV funds not disbursed to recipients by the end of the third business day are considered excess cash. The Department of Education (ED) allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). From February 20, 2024 to April 9, 2024, total cash drawdowns for student financial aid consistently exceeded aid disbursements to recipients (expenditures) by an amount less than one percent of prior year drawdowns. The excess cash during this period was not returned to ED within seven days. Explanation of Agreement/Disagreement: Management concurs with the finding and has implemented additional controls within the drawdown process that includes a secondary review and approval of the amount and timing of each drawdown. Officials Responsible for Ensuring Corrective Action: Karen Smith, Assistant Vice President for Administration and Finance and Controller Planned Completion for Corrective Action: Excess cash was no longer on hand as of June 30, 2024. Corrective internal controls have been implemented as of October 1, 2024 to prevent further instances of noncompliance. Plan to Monitor Completion of Corrective Action: Management has implemented controls within the drawdown process that includes a secondary review and approval of the amount and timing of each drawdown. This will ensure that limits are not exceeded and, if there are instances that require a return of funds, provide oversight to ensure the timely return of those funds.

Views of the responsible officials and planned corrective actions Management agrees that a centralized reconciliation control process should be in place, given the large amount of grants that the City has been awarded and will continue to apply for in the future. Management will work to develop those procedures and communicate with other departments.

Type of Finding – Significant Deficiency in Internal Control Over Compliance. Condition/Context – Internal control procedures over eligible disbursements did not ensure compliance with federal awards. An employee reimbursement was billed twice, and employee bonuses, which are not allowable costs, were included within the reimbursement request. Contact Person – Amy Schaefer, VP of Finance – amys@jaaz.org – (602) 616-0873 Corrective Action Plan – Management has implemented procedures to verify that the expenditures that are requested for reimbursement are accurate and are allowable under the Uniform Guidance. Review procedures will be used to help ensure that only allowable salaries expenses are included in reimbursement requests.