Corrective Action Plans

TOFMHS concurs with the finding. The excess drawdowns were the result of accounting entries to record refunds, or other adjustments which reduced previously allowable expenses. Subsequent drawdowns should have been reduced to offset these adjustments. TOFMHS will implement ACF-IM-HS-23-01 (Treatment of Rebates, Refunds, Discounts), and prevent an recurrence of this issue in the future. Corrective Active Taken: TOFMHS returned the $51,664 to the Payment Management System on January 16, 2025 in accordance with the referenced Information Memorandum. Drawdowns will be based upon actual expenses and disbursed within 3 business days. Responsible Person: Finance Director with oversight by the Program Director.

Finding #2023-002 Cash Management: Douglas Wilson identified that there was no indication that requests for reimbursements were reviewed or authorized prior to submission. Per the recommendation of Douglas Wilson, we have established policies and procedures for cash management over federal funds and implemented internal controls that specifically address the review and approval of cash withdrawals to include retaining documentation supporting those cash withdrawals. The Controller (or CFO in the absence of the Controller) will have the responsibility to retain records pertaining to the communication demonstrating the review and approval of the cash drawdowns of federal grant funding. The Staff Accountant or the Accounting Manager will also retain any supporting documents related to communication of the review and approval process for cash drawdowns of federal grant funding. Responsible official: Sydney Blair, Chief Executive Officer, 406.791.9603 Expected completion date: June 30, 2025

Finding #2023-001 Allowable Costs and Cost Principles: Douglas Wilson was unable to determine if the Center complied with the 15% requirement or the $25,000 technical assistance limit for the CCBHC grant. Douglas Wilson was also unable to test a sample of direct costs charged to the program because transaction details were not provided. Per the recommendation of Douglas Wilson, we have updated the Center’s existing financial policy and procedures to include language specifically related to how the Center will retain documentation to support costs that are charged to the CCBHC grant, and also track and monitor compliance with the 15% and $25,000 maximum requirements for the grant (see Financial Policies and Procedures Policy A-14). Responsible official: Sydney Blair, Chief Executive Officer, 406.791.9603 Expected completion date: June 30, 2025

Management has acknowledged a breach in protocol and deposited the current year’s surplus cash on February 6, 2025.

2023-005 Drawing of Capital Funds RHA is committed to ensuring that all capital fund expenditures are processed and distributed within a maximum of three days. By doing this we will stay in compliance with HUD regulations. Name of Responsible Person: Tami Lucia Executive Director Implementation date: October 2024

Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School. Corrective Action Planned: In January 2023 DESE sent an auditor to review the Medford School Nutrition Program. Before this review, there was significantly limited oversight by the central office finance team. Almost no documents were prepared before the review as required by DESE. As a result of this audit a 58-item, 19-page Corrective Action Plan was issued to the district. A new district leader was assigned for departmental oversight. The district then had weekly meetings with DESE to address the corrective action plan, for this was the single largest CAP DESE has issued to any district of our size. Nearly $1.3 million in reimbursements were withheld from the district from approximately November 2022 through the end of the Fiscal Year. DESE issued the reimbursements with a nominal penalty during the summer of 2023. At the end of FY23, the district terminated the director of the program. We are now training several individuals in the MCPPO program for enhanced oversight. DESE forced an immediate return audit for FY24. This was an exceptional action as DESE has only rarely done this. The same reviewer attended and noted significant improvements as a result of district actions undertaken. As relates to this particular finding, the School Department has purchased and is consistently using a point of sale system for students to purchase their meals. The system is used to track all transactions. Anticipated Completion Date: 2/17/2025 Contact: Peter Cushing, Assistant Superintendent

Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend the Organization utilize one spreadsheet for allocating payroll costs and implement additional controls to ensure the allocations to Federal grants accurately reflect the actual hours worked. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ventures has stopped utilizing multiple allocation spreadsheets and will only use one spreadsheet. This single spreadsheet will be utilized for all payroll cost allocations and will be housed within the finance department under restricted access. The allocation of expenses to grants will be based on the FTE count per the payroll allocation spreadsheet. Changes to the allocations will be documented and shared with the Executive Director. Name(s) of the contact person(s) responsible for corrective action: Theo Everheart and Monique Valenzuela Planned completion date for corrective action plan: 07/31/2024

FA 2023-004 Strengthen Controls over Financial Reporting Compliance Requirement: Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A210010 (Year: 2022) SO10A220010 (Year: 2023) Questioned Costs: $84,283 Repeat of Prior Year Finding: FA 2022-004, FA 2021-002, FA 2019-002 Description: The School District did not file accurate completion reports for the Title I Grants to Local Educational Agencies program. Corrective Action Plans: District office has put procedures in action to make sure that all drawdowns are in line with expenditures. All draw down packets will be viewed and signed off by federal program director. This packet will include detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Torrence H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2023-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A210010-21A (Year: 2022) SO10A220010 (Year: 2023) Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2022-003, FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and School Emergency Relief Fund programs. Corrective Action Plans: District office has put procedures in action to make sure that all drawdowns are in line with expenditures. All draw down packets will be viewed and singed off by federal programs director. This packet will include detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Torrence H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Invoices received by NYSSA pertaining to Federal Grants will be given to the Deputy Director, Lucas Ashby for review. (current procedure). Invoices to be paid will be entered into Quickbooks financial software by the Finance Manager, Jon Greenwalt (current procedure). Checks for payment to grant vendors follow the same procedures and processes as listed in 2022-001 above, numbers 1 and 2 [New procedure implemented]. Based on the timeline of the 2022 audit, many of the corrective actions were made in late Oct/November 2023.

The Project Administrator will reimburse the funds to the Montana Department of Natural Resources (DNRC), based on directions provided by DNRC. The Project Administrator will work with the outside accountant on record keeping of the Authority. Responsible Officials: Monty Sealey, Project Manager and Melissa Carlson, Accountant Expected Completion Date: by June 30, 2025

Finding 2023 – 001: Restatement to Fund Balance Condition: During audit fieldwork, our testing resulted in a restatement of fund balance in order to correct insurance improperly recorded in prior years. Plan: The Village will implement internal controls to properly record insurance expenses, payables, and prepaid expenses on a timely basis prior to audit fieldwork. Additionally, the Finance Director will provide monthly reviews of the financial statements. Anticipated Date of Completion: December 31, 2024

CAMcare has made significant changes to the patient payment collection process. Updates were made to the Patient Payments, Refusal to Pay, Waiver/Reduction of Charges Policy, Sliding Fee Scale Policy, and Patient Payments Policy, and a Patient Payments Policy was introduced. The new EMR system allows for individual Patient Service Representatives (front desk personnel) to monitor management's adherence to collection efforts.

Identification of federal programs 10.558 - Child and Adult Care Food Program (CACFP) Condition The Organization does not retain documentation of review of supper meals and snacks uploaded for reimbursement. Views of Responsible Officials: Management agrees with the finding and observation. Contact Person: Fendy Wogu, Finance Controller Proposed Completion Date: October 31, 2024

Finding No 2023-001 Name of Responsible Party Fred Gibbs FKGibbs Company, LLC PO Box 410312 Kansas City, MO 64141 Fred@fkgibbs.com M: 913.709.1811 Views of Responsible Official and Corrective Action Management will fund residual receipts within the required timeframe going forward. Expected Date of Completion: N/A

Finding No 2023-002 Name of Responsible Party Fred Gibbs FKGibbs Company, LLC PO Box 410312 Kansas City, MO 64141 Fred@fkgibbs.com M: 913.709.1811 Views of Responsible Official and Corrective Action Agrees with the recommendation Expected Date of Completion Not determined

Finding No 2023-001 Name of Responsible Party Fred Gibbs FKGibbs Company, LLC PO Box 410312 Kansas City, MO 64141 Fred@fkgibbs.com M: 913.709.1811 Views of Responsible Official and Corrective Action The Project did not make the required deposit to the residual receipts accounts and still is not in compliance for the year ending 06-30-2023. Expected Date of Completion: unknown

Moving forward, the NRHP CFO will submit requests for reimbursements timely

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) Paypal, Frost, Forte - Management continues to work with law enforcement to obtain misappropriated funds from PayPal, and other potential accounts. As indicated, investigators met with the CEO, staff, Frost Bank, and the Board to obtain information regarding these accounts. It is our understanding that they may meet with prior Via Hope executives as well. We will update the auditors when more information is provided. e) 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.

FA 2023-003 Improve Controls over Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The School District made cash drawdowns in excess of immediate cash needs for the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The district will implement procedures to ensure all drawdowns align with expenditures. The program director or coordinator will view and sign all draw- down packets. The packets will include detailed expenditure reports for the month and year-to-date of the expenditures that are a part of the requested drawdown. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

FA 2023-001 Improve Controls over Financial Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The accounting procedures of the School District were insufficient to provide adequate internal controls over multiple control categories. Corrective Action Plans: Management will review, design, and implement procedures to strengthen the internal controls over the accounting functions to ensure transactions are properly processed and reported. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

StartUpNV, Inc. Corrective Action Plan Year Ended December 31, 2023 2023-001 System of Internal Controls and Resulting Disclaimer of Opinion Criteria: The Internal Revenue Service (IRS) has defined a charitable organization as “organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, educational, or other specified purposes.” As a result of an entity being recognized as an exempt charitable organization, the nonprofit is entitled to favorable treatment(s) reserved for such entities (e.g., reduced taxation). Condition: The Organization was unable to produce sufficient appropriate audit evidence to support its assertion that revenues and expenditures related to StartUpNV, Inc. exclusive activities. Cause: The system of internal controls implemented by the Organization was not well-defined and did not contain appropriate segregation of duties amongst non-interested parties. Effect: The Organization was unable to provide sufficient appropriate audit evidence to support issuance and receipt of an unmodified audit opinion. This led to delays in the overall audit process resulting in late filing of the Data Collection Form to the Federal Audit Clearinghouse (FAC). Recommendation: We recommend management design and implement a system of internal controls whereby clear delineation between StartUpNV, Inc. activities and those of interested parties is supported. Further, we recommend that this system of internal controls be well documented and consistently applied. Risk assessment as it relates to general exempt organization compliance, as well as specific compliance related to federal award receipts, should be consistently performed by appropriate, competent personnel. With these systems in place, StartUpNV, Inc. will be better positioned to support regulatory expectations and requirements. Responsible official: Maggie Saling Title: Chief of Operations Email: maggie@startupnv.org Phone number: 805.302.1862 StartUpNV will create a policy document that shows procedures for internal control of expenditures that includes independent oversight. StartUpNV plans to contract with an outside party to perform an independent review and approval of expenditures prior to grant reimbursement requests and establish formal, documented procedures governing this process. Due to the recent resignation of the board treasurer, the incoming treasurer will assume oversight responsibility for this independent reviewer and budgetary and expenditure controls. The current Executive Director plans to announce his retirement from the non-profit organization – and announce a Board of Directors search process for his replacement. The appointment of a new Executive Director will address the requirements for the segregation of duties and independence. The Chief of Operations will provide guidance and support to the new Executive Director, ensuring a smooth transition of responsibilities through her planned retirement by the end of the year. The search and hiring process for a new Executive Director is anticipated to be completed within a timeline of 6 months.

Finding 2023-03 Lack of Documentation to Support Expenditures Condition: The Organization failed to maintain financial records that properly substantiated expenditures which limited the ability to test several compliance requirements as part of audit procedures. These issues were most prevalent in testing direct disbursements. As part of audit procedures, 81 transactions were selected in a testing sample from a population which included 315 transactions. Of the 81 transactions tested, the Organization was unable to provide sufficient source documentation to support 21 of the transactions. Further, vendor and contract files were not consistently maintained and failed to provide adequate support to detail the history, method, and selection of procurement. Corrective Actions Taken or Planned: - Collaborate with the CPA firm to develop a standardized process for recording and tracking gift card transactions and allotments, ensuring accountability and traceability. - Add LaKisha (Executive Administrative Assistant) to QuickBooks with specific responsibilities for recording receipts, requisition forms, and matching these to corresponding transactions. Provide QuickBooks training for the Executive Assistant to strengthen understanding and ensure timely and accurate documentation of financial activities. - Develop and enforce a formal policy requiring comprehensive documentation (e.g., invoices, receipts, contracts) for all expenditures over a certain threshold (e.g., $500 or higher). This policy will include requirements for approval and justification prior to disbursement. - Require all staff to complete requisition forms for supplies or purchases in advance of procurement. These forms will include itemized details, purpose of purchase, and approval signatures. - Update processes to ensure vendor and contract files include critical details: procurement history, selection method, contract terms, and vendor agreements. These files will be consistently maintained and reviewed for completeness. - Strengthen the credit card usage process to require staff to submit itemized receipts, purpose of purchase, and pre-approval for all credit card transactions. This will include monthly reconciliations and management review of all credit card statements. - Implement periodic internal reviews to ensure compliance with the new documentation and procurement processes. The CPA firm will assist with quality checks and provide ongoing guidance.

Views of Responsible Officials: Federal grant requests and reporting is the function of three teams: Programs, Development and Finance. Prior to the hiring of the VP-Finance, the Associate Director, Grants Management and Compliance met with the Associate Director, Partnerships on a quarterly basis to discuss required program spend reimbursements and projected program cash needs prior to submitting the formal requests. With the onboarding of the new VP-Finance, internal review processes were changed to incorporate more robust segregation of duties, alignment with the internal cash management policies and procedures and formal review of drawdown requests prior to submission. The VP-Finance became a permanent employee in October 2024 so the anticipated completion date of this corrective action is the end of the respective calendar quarter (December 31, 2024).

Contact person(s) responsible: Nicole Smith, Operations Manager Corrective action planned: We will prepare the manual of financial and federal compliance policies and procedures (including cash management, allowable costs, and procurement) as required by the Uniform Guidance. Pertinent employees will be trained to use this manual to ensure compliance. Anticipated completion date: December 31, 2024