Corrective Action Plans

2023-002 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has contracted with an outside firm that specializes in SBOA compliance, as well as Federal Award Compliance in line with Uniform Guidance. The firm will assist in the development of the required manuals, policies, procedures and review processes. The current estimated completion date is February 28, 2025.

Auditor’s Recommendation: The Organization document internal control over compliance procedures and document written procedures to ensure compliance with 2 CFR 200.305. Corrective Action: Implement Policy A10 – “Grant Management Protocols.” Utilize Donor Database for managing subawards. Responsible for Corrective Action: Finance Team (Outsourced accounting firm, Operations Manager, Executive Director) Anticipated Completion Date: December 31 2024

Eastern Carolina Human Services Agency, Inc. Corrective Action Plan For FY Ending June 30, 2023 Section II. Financial Statement Findings. 1. Finding 2023-001 - U.S. Department of Health and Human Services, Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: Internal control processes over financial accounting did not ensure that all transactions were properly recorded. Internal control processes over financial accounting did not ensure that key accounts were reconciled or received on a periodic basis. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director. Action Plan: After review/monitoring of the previous Finance Officers duties and responsibilities, it was determined that the internal control processes of the finance department were not carried out properly to meet the requirements of 2 CFR Part 200 Section 200.302. Therefore, the agency terminated the Finance Officer. The agency immediately began the search for a new Finance Officer via Indeed and other employment hiring agencies. This process took much longer than expected which left an unexperienced Accounting Technician to operate the Finance Department along with limited finance knowledge of the Executive Director. After several advertisements for the vacant position the agency interviewed numerous applicants and was finally able to hire the current Finance Officer. The Finance Officer has worked continuously to insure that the internal control process of the department is implemented by making sure all accounts are reconciled and reviewed with supporting evidence of each review. With this process back in place, management and the Board of Directors will review and sign off on each account's financial statements. Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-002 - U. S. Department of Housing and Urban Development Voucher Cluster, Assistance Listing #14.871/14.879 Statement of Condition: For the year ended June 30, 2022, the Organization did not submit their audited financial statements to HUD by the required deadline. For the year ended June 30, 2023, the Origination did not submit their unaudited or audited financial statements to HUD by the required deadline. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: The submittal of the GAAP-based unaudited and audited report for FY ending June 30, 2022, was a management oversight due to the lack of a Finance Officer in place. The agency currently has a Finance Officer in place who will submit timely GAAP-based unaudited and audited financial information electronically to HUD via the Financial Assessment Sub-System (FASS-PH). Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-03 - U.S. Department of Health and Human Services Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: The origination did not submit the data collection form and required reporting package to the Federal Audit Clearinghouse (FAC) for the year ended June 30, 2023, by the required due date. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: Management will ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. To further ensure this finding is resolved, training for the Finance Officer/Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Section II - Findings relating to the financial statements which are required to be reported in accordance with generally accepted government auditing standards. 1. Finding 2022-001 Statement of Condition: Controls over the vendor payment process were not properly followed. Action Plan: Submitted previously with Financial Statements and Independent Auditor's Report FY Ended June 30, 2022. Current Status: Corrected The Management Department (Finance Officer and Executive Director), with the supervision of the Board of Directors Finance Officer, will continue to make every effort necessary to meet all HUD submission as required, in order to be in compliance with all HUD rules and regulations. Respectfully submitted, Trudy Murray Executive Director

Eastern Carolina Human Services Agency, Inc. Corrective Action Plan For FY Ending June 30, 2023 Section II. Financial Statement Findings. 1. Finding 2023-001 - U.S. Department of Health and Human Services, Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: Internal control processes over financial accounting did not ensure that all transactions were properly recorded. Internal control processes over financial accounting did not ensure that key accounts were reconciled or received on a periodic basis. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director. Action Plan: After review/monitoring of the previous Finance Officers duties and responsibilities, it was determined that the internal control processes of the finance department were not carried out properly to meet the requirements of 2 CFR Part 200 Section 200.302. Therefore, the agency terminated the Finance Officer. The agency immediately began the search for a new Finance Officer via Indeed and other employment hiring agencies. This process took much longer than expected which left an unexperienced Accounting Technician to operate the Finance Department along with limited finance knowledge of the Executive Director. After several advertisements for the vacant position the agency interviewed numerous applicants and was finally able to hire the current Finance Officer. The Finance Officer has worked continuously to insure that the internal control process of the department is implemented by making sure all accounts are reconciled and reviewed with supporting evidence of each review. With this process back in place, management and the Board of Directors will review and sign off on each account's financial statements. Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-002 - U. S. Department of Housing and Urban Development Voucher Cluster, Assistance Listing #14.871/14.879 Statement of Condition: For the year ended June 30, 2022, the Organization did not submit their audited financial statements to HUD by the required deadline. For the year ended June 30, 2023, the Origination did not submit their unaudited or audited financial statements to HUD by the required deadline. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: The submittal of the GAAP-based unaudited and audited report for FY ending June 30, 2022, was a management oversight due to the lack of a Finance Officer in place. The agency currently has a Finance Officer in place who will submit timely GAAP-based unaudited and audited financial information electronically to HUD via the Financial Assessment Sub-System (FASS-PH). Additionally, the agency has approved and scheduled HUD training for the Finance Officer through Nan McCay. Further, financial and accounting training for the Finance Officer/ Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Finding 2023-03 - U.S. Department of Health and Human Services Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879. Statement of Condition: The origination did not submit the data collection form and required reporting package to the Federal Audit Clearinghouse (FAC) for the year ended June 30, 2023, by the required due date. Contact Person: Ashlee Graziano, Finance Officer, or Trudy Murray, Executive Director Action Plan: Management will ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. To further ensure this finding is resolved, training for the Finance Officer/Finance Department has already been requested through the agency's local HUD Field Office analysis in Greensboro, NC. Section II - Findings relating to the financial statements which are required to be reported in accordance with generally accepted government auditing standards. 1. Finding 2022-001 Statement of Condition: Controls over the vendor payment process were not properly followed. Action Plan: Submitted previously with Financial Statements and Independent Auditor's Report FY Ended June 30, 2022. Current Status: Corrected The Management Department (Finance Officer and Executive Director), with the supervision of the Board of Directors Finance Officer, will continue to make every effort necessary to meet all HUD submission as required, in order to be in compliance with all HUD rules and regulations. Respectfully submitted, Trudy Murray Executive Director

Finding: 2023-010 Environmental Finance Center Grants – Assistance Listing No. 66.203 U.S. Environmental Protection Agency Grant No. 539001D, Grant period July 1,2022 - September 30, 2023 Grant No. 5127620, Grant period October 1, 2022 – September 30,2023 Grant No. 5126607, Grant period July 1,2022 - September 30, 2023 Description of the Findings: For the period from October 2022 thru May 2023 U.S. Water Alliance did not have a timekeeping system in place. A timekeeping system was implemented in June of 2023, that provides for employees to record hours worked for specific cost objectives, including Federal grants. There are limitations to the timekeeping system’s capabilities. One is no availability to run timesheet reports for closed grants after the grant period ended. Second is the need to manually adjust hours transferred from the timekeeping system to payroll processing system due to semi-monthly payroll processing and the need to have total number of hours equal to 86.67 for salaried employees. For these three awards, budget estimates or relative level of effort by percent of full-time employees and active projects were used throughout the entire grant period, even after the timekeeping system was put in place. No reconciliation between the budget estimates or relative level of effort by percent of full-time employees and active projects and the hours recorded in the timekeeping system was completed even for the period in which the timekeeping system was in place. Views of Responsible Official(s) and Planned Corrective Actions: A new timekeeping system was implemented in June 2023 to allocate work hours specific to cost objectives, including Federal Grants. While there are limitations to the system, the allocations are transferred from the timekeeping system upon supervisor approval to the Prism (HRIS) Portal and used to prepare payment vouchers. From the HRIS system, we can produce labor allocation reports reflecting how the time was originally allocated in the timekeeping system. The US Water Alliance indeed operates on a semi-monthly payroll period. It has allowed the Alliance to have fixed pay dates though they may not fall on the same day of the week each month. If the pay date falls on a weekend or holiday, the pay date is typically the business day prior. Because all months are not the same length, the size of the paycheck could vary in that the first paycheck could cover 13-14 days and the second paycheck could cover 15-16 days. To eliminate the variation in the size of the paycheck, specifically for salaried employees, the total yearly salary is evenly divided between 24 payments resulting in the same paycheck amount each time. This division results in 86.67 hours paid in each paycheck and will at times require our payroll partner to adjust the hours allocated downward or upward to equal 86.67. In the rare case that work hours are adjusted upward, the work hours are allocated to the primary funding source for the position. The process has worked traditionally as the Alliance has no hourly employees. Specifically for the three awards referenced, reconciliation between the budget estimates, relative level of effort by percent of full-time employees and active projects, and the hours recorded in the timekeeping system were completed. Staff opted to continue reporting on relative level of effort by percent of full-time employees as opposed to shifting as the timekeeping system was very new and staff experienced a significant learning curve. Additionally, there were only two months left in the grant period. Relative level of effort was carefully documented internally via calendars, Monday.com project management software, and Excel spreadsheets. Since its implementation, staff have been better trained in the use of the timekeeping system. We are also transitioning to a new timekeeping system in December 2024 with enhanced reporting and ease of use. The Alliance will also shift to a bi-weekly payroll period effectively reducing the need to adjust work hour allocations upward or downward to equal 86.67 hours. Completion Date: June 2023 Responsible Official(s): ShaQuina Davis

Corrective Action Planned: In conjunction with the timely submission of the audit report, if DCHC expends federal funding of $750,000 or more in a fiscal year, the audited annual financial report and data collection form will be submitted to the Federal Audit Clearinghouse in a timely manner in accordance with federal regulations. Contact Person or Responsible Party: Wilbert Thomas, President and CEO Anticipated Date of Completion: June 30, 2025 29

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement new policies and procedures to ensure that all expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies for any new ARPA contracts. Most all of the 2023 expenditures were part of contracts that were already in place when the 2022 findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Sherri Crow, Director of Budget and Finance Planned completion date for corrective action plan: December 1, 2024

Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG, will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by March 31, 2025.

2023-003: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Noncompliance, Material Weakness Condition: The school lacked adequate internal controls over its accounting disbursements to ensure that a) all financial activities were properly processed and recorded and b) the School remained in compliance with federal requirements. Context: During our review of the school’s accounting records and internal controls, as well as through management inquiry, we noted the following:  For eight of 25 accounts payable transactions tested out of the 15.042 grant, the school did provide adequate documentation to support the allowability of the expenditure.  For twenty-five of 25 accounts payable expenditures tested out of the 15.046 grant, the school paid amounts to and on behalf of illegitimate board members, totaling $82,127.  For twenty-five of 25 payroll disbursements tested out of the 15.046 grant, the school paid board meeting stipends to illegitimate board members, totaling $9,750. Repeat Finding: No. Action planned in response to the finding: Management will evaluate its internal controls over records management to ensure that all accounts payable disbursements are properly supported, and School Board expenditures are only paid out to and on behalf of eligible individuals. Planned completion date for a corrective action plan: June 30, 2024 Name of the contact person responsible for corrective action: Marie Rose, Principal

Management acknowledges the finding and has initiated steps to address the identified issues. During CY2024, management made a strategic decision to outsource the entire fiscal operations to industry lead BTQ Financial services. The cooperation with the new fiscal vendor will increase on compliance and timely financials reports that overall ensure timely audit completion and submission of DCF report.

Management strives to operate within a model of continuous improvement and will review and improve processes appropriately to provide for timely reporting on a go-forward basis.

a. Comments on the Findings and Each Recommendation Due the ongoing impact of the COVID 19 pandemic, the Organization and CHR Consulting Services, Inc. (“CHR”), the entity responsible for maintaining the books and records of the Organization, experienced staffing shortages due to retirements and medical leave. In addition, as a result of the ongoing impact of the COVID 19 pandemic, the Organization continued to experience noncompliance with certain debt covenants in 2023 and first half of 2024. In addition, the Organization had several vendor or liabilities, including the Pennsylvania bed tax liability that required resolution prior to the issuance of the audited financial statements. b. Action(s) Taken or Planned on the Finding The Organization and CHR have been able to recruit additional staff and CHR has added additional supervisory personnel to oversee the financial reporting and audit process. In an effort to improve communications with the Grantor, in August 2023, the Organization began providing monthly financial and operational information. In addition, monthly calls were implemented with the representatives of the Grantor, discussing key operational and performance measures. While key issues were identified and discussed with the Grantor, the Grantor has not been able to provide waivers for such noncompliance with covenant requirements. As noted in Note 2 the audited financial statements, the financial performance of the Organization has improved, allowing the Organization to enter into long-term payment plans for the resolution of the key liabilities of the Organization. It is anticipated that the audit for 2024 and related forms will be issued within the allowable time period in the loan agreements.

Management will produce written procurement policies and procedures for federal awards and subawards in compliance with the Uniform Guidance and Single Audit Standards.

We are in process of submitting the required operating budget and self-certification letter to the USDA. Anticipated Completion Date- 12/31/2024 Completed.Responsible Contact Person-Kathleen Boyce, CFAO

Corrective Action: The district will ensure that all supporting documents will be stored electronically first and stored physically as a secondary option. Each department will be responsible for maintaining a copy of all supporting documentation. All checks and contracts will be included in the procurement packets for all expenditure. We are currently implementing this process and strengthening internal controls. Responsible Parties: Avery Johnson, Business Manager Robert Sanders, Superintendent Corrective Action Start Date: October 31, 2024

Finding 2023-003 Corrective Action: Before any expenditure is obligated, all revisions/amendments will be approved in MCAPS first. The business Manager, Federal Programs Director, and Superintendent will ensure MDE's approval is tangible before any obligations. We will implement a tool that allows this process to be measured daily. Responsible Parties: Avery Johnson, Business Manager Robert Sanders, Superintendent Tiffany Lanier, Federal Programs Director Corrective Action Start Date: October 31, 2024

Stoneboro Development Corporation Stoneboro, Pennsylvania November 18, 2024 U.S. Department of Housing and Urban Development City Crescent Building 10 South Howard Street Baltimore, Maryland 21201-2505 Stoneboro Development Corporation respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended June 30, 2023 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2023-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely payment of the mortgage payments and escrow deposits. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Additionally, the new management company is working with the lender to make additional mortgage payments and escrow deposits as cash flow permits. Finding 2023-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reported package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. Finding 2023-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due dates. Action Taken: We agree with Finding 2023-003 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the annual financial reports to HUD are submitted once the audits are back on track with the scheduled due dates. Finding 2023-004: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely monthly deposits to the replacement reserve account are made as required. Action Taken: We agree with Finding 2023-004 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Finding 2023-005: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all disbursements from project operations. Action Taken: We agree with Finding 2023-005 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all disbursements from project operations. Finding 2023-006: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all cash receipts of the project. Action Taken: We agree with Finding 2023-006 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all cash receipts of the project. If HUD has questions regarding this corrective action plan, please call (412) 246-9213. Sincerely yours, Trisha Jester Director of Multifamily Housing Arbors Management, Inc. Managing Agent

Stoneboro Development Corporation Stoneboro, Pennsylvania November 18, 2024 U.S. Department of Housing and Urban Development City Crescent Building 10 South Howard Street Baltimore, Maryland 21201-2505 Stoneboro Development Corporation respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended June 30, 2023 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2023-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely payment of the mortgage payments and escrow deposits. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Additionally, the new management company is working with the lender to make additional mortgage payments and escrow deposits as cash flow permits. Finding 2023-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reported package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. Finding 2023-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due dates. Action Taken: We agree with Finding 2023-003 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the annual financial reports to HUD are submitted once the audits are back on track with the scheduled due dates. Finding 2023-004: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely monthly deposits to the replacement reserve account are made as required. Action Taken: We agree with Finding 2023-004 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Finding 2023-005: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all disbursements from project operations. Action Taken: We agree with Finding 2023-005 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all disbursements from project operations. Finding 2023-006: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all cash receipts of the project. Action Taken: We agree with Finding 2023-006 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all cash receipts of the project. If HUD has questions regarding this corrective action plan, please call (412) 246-9213. Sincerely yours, Trisha Jester Director of Multifamily Housing Arbors Management, Inc. Managing Agent

The University agrees with the finding. The University has had a significant amount of staff turnover and reorganization in FY 2023 in the financial aid office. The Interim Director of Financial Aid is collaborating with the controller’s office to make sure that the University has internal controls in place over Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal statutes, regulation and terms and conditions of the federal award. The University is investing in making sure that the Financial Aid Office is staffed and create policy and procedure that assure that we improve internal controls on the Pell process.

Finding 2023-003 Matching, Level of Effort, Earmarking, Program Income and Reporting Aging Cluster (ALN 93.044/93.045/93.053) Corrective Action: Management is in agreement with the finding. Management will ensure the necessary reports are filed with the granting agency in a timely fashion and amounts reported are accurate. Management anticipates corrective action to be in place by 01/01/2025. Responsible party: Mary Bateman, Controller.

ʻAha Pūnana Leo is reviewing grants and awards from federal and nonfederal sources and identifies and tracks all federal funds. We will strengthen our internal controls over reviewing the accuracy and completeness of the SEFA for financial reporting purposes. We have since implemented an additional review step in the grant set-up process to specifically address the proper classification of revenue for each new funding source.

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the four required quarterly P&E reports and the annual Recovery Plan Performance Report during the audit period; however, a single employee prepared and submitted each report without a review or oversight process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Chris Cloud, Chief of Staff Contact Phone Number and Email Address: 260-449-4752 / chris.cloud@allencounty.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct Finding 2023-003, the Chief of Staff to the Board of Commissioners will have the Controller to the Board of Commissioners review the P&E Reports and the Recovery Plan Performance Report prior to being electronically submitted to the Department of Treasury via its State and Local Fiscal Recovery Funds portal. If errors are discovered by the Controller, the Chief of Staff will correct the electronic entry prior to submission. Anticipated Completion Date: This CAP will be completed by October 31, 2024, the deadline for submitting the third quarter 2024 P&E Report.

FINDING 2023-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Summary of Finding: (copied from SBOA Findings document provided) The Allen County Department of Health (Department of Health), a department within Allen County, was awarded the Health Issues and Challenges grant through the Indiana Department of Health financed through the American Rescue Plan Act (ARPA) for the purposes of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. As part of sound management of the Federal award, the Department of Health was responsible for implementing a system of internal control that would ensure compliance with the applicable requirements. The Department of Health did not properly design or implement such a system. The Department of Health was required to submit data through the online portal, National Electronic Disease Surveillance System (NEDSS) Base System (NBS), monthly beginning in October 2022. The submitted data included program specific metrics relating to patient case management of certified Elevated Blood Lead Levels (EBLLs). The Department of Health was also required to ensure environmental investigation activities completed, including risk assessments and environmental inspections, were documented in the Indiana I-LEAD database monthly by a licensed Lead Risk Assessor. Environmental investigation activities performed by the Department of Health were documented in the Indiana I-LEAD database by a licensed Lead Risk Assessor who was an employee of the Department of Health. Similarly, case management activities performed were documented in the NEDSS Base System (NBS). Once activities were documented in the I-LEAD and NBS systems, the activities were further documented in a spreadsheet by the Lead Risk Assessor (for I-LEAD activities) and the Case Management Coordinator (for NBS activities). The spreadsheet was reviewed by the Director of the Environmental Services Division and the Finance Director monthly. The Finance Director then used the spreadsheet to prepare the monthly reimbursement requests and sent the monthly reimbursement requests to the Indiana Department of Health. We determined through inquiry with the Director of the Environmental Services Division and the Finance Director that while there was a review of the monthly spreadsheet, there was not a second review of the spreadsheet back to the activities reported in I-LEAD and NBS for accuracy. Additionally, the Finance Director prepared and submitted the reimbursement requests to the State without a second review or oversight process in place to prevent, or detect and correct, errors prior to submission. The lack of internal controls was a systemic issue throughout the audit period. Recommendation We recommend that management of the Health Department design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure reports are complete and accurate. ………………………… Contact Person Responsible for Corrective Action: JENNIFER MILLER (Finance Director) Contact Phone Number and Email Address: 260-449-7358 (Jennifer.miller@allencounty.us) Views of Responsible Officials: We concur with the finding Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: We were unaware of a requirement for a secondary review of each document/spreadsheet/database input/task that was conducted prior to submission to the Finance Director (defining the completed cases for which to invoice the State), and a requirement for a secondary review of the invoice/billing documents prior to submission to the State. We were informed that the State review process (as was described to SBOA staff) was the check and balance needed which ensured we had appropriately entered the data into the required database(s) and that we had then subsequently billed for those very same appropriately completed and entered cases. However, when we were informed of the outcomes of the SBOA audit and the subsequent need for a corrective action plan (CAP) relative to their findings, we moved quickly to begin the development of the CAP -- as we do now understand that despite the inaccurate instructions we were given, we did not appropriately do what the law requires locally relative to ensuring accurate completion of duties under grant contracts before submission for reimbursement. THE PLAN (which will be added as a new “Grants” section in our existing Finance Internal Controls policies): For all grants (reimbursable or deliverables-based), once a contract is near completion or upon execution, a primary and secondary staff member will be identified for each step of the database entry (as an example, and this will follow whatever the duties are defined by the grant and a primary responsible staff member will be defined per grant duty needs) as well as for the invoicing/billing documentation process. The primary staff member(s) will be responsible for doing what is defined in the grant contract (a duty, task, data entry, invoice creation, etc.) and the secondary staff member will be responsible for verifying the work of the primary staff member(s). (In some cases, when there are diverse duties and more than one primary staff member is needed to do the duties of the grant, there may be several primary staff members assigned to various duties as needed) If disparities are encountered (such as errors or omissions) in any step related to the above duties, they will first be reported the primary staff member for likely easy correction or resolution. If a pattern exists or repetitive errors are identified through the review and verification process, the secondary reviewer will report the issue(s) to the Department Administrator to make a determination as to whether the primary staff member’s duties are transferred to another staff member, or if the person is simply re-educated. The goal will be to ensure there is an appropriate check and balance step (as well as remediation/correction step if warranted) in place for all tasks and documentation completion as it relates to grant-funded duties and invoicing. Anticipated Completion Date: We will follow this practice for any new grants accepted by the Allen County Department of Health effective 9/17/2024.

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan Corrective action plan to ensure enrollment reporting is completed timely and accurately I. The admissions team sends a list of all enrolled students 2. Financial aid will manually enter the student's information into campus IVY 3. Campus IVY updates the student's status in NSLDS every 30 days. 4. If a student withdraws from Community Christian College, financial aid will manually update the student status into campus IVY 5. NSLDS is updated upon completion of the withdrawal This process will ensure that Community Christian College updates enrollment statuses for every student timely

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The following is the procedure that the College will be implementing to ensure that student withdrawal calculations are performed accurately and returned within 30 days: I. The registrar will send a list to financial aid of all students that have dropped by end of day every Thursday of each week. The list will include date of determination (DOD) and last date of attendance (LOA) of each student b. DOD wiII be within 14 days of student LOA 2. Upon receipt of the list financial aid will complete the following for each student: a. Gather student's current ledger card b. Gather student's current Transcript c. Complete a cover sheet which indicated the current loan period of the student. d. Financial aid will send over items to yd patty processor in order for R2t4 calculation to be completed (Campus IVY) no later than Wednesday of the following week by end of business day. 3. Campus IVY will complete the R2T4 3-5 business days upon receipt and conduct the following: a. If a refund is required- campus IVY will schedule the refund, update student account and send to school. b. School (student accounts) will review the refund, update student account and monies will be placed in the operations account and sent back to GS. c. If a refund is not required based on the R2T4 results, Campus IVY will notate the student account. This corrective action plan will allow Community Christian College to complete the drop process for each student within 30 days from LOA.