Corrective Action Plans

The Corporation will register and apply for PPP Forgiveness via the SBA PPP Direct Forgiveness Portal or contact SBA Customer Service at 877-552-2692.

The Management Agent will properly review all statement of financial position and statement of activity accounts to determine no material misstatements on a monthly basis.

Management Response #2022-017: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, which made it extremely difficult to find supporting documentation. Corrective Action Plan: The procedures adopted in 2024 will be formally documented and published that will ensure proper cost sharing or matching are clearly understood and defined. The requirements for matching as well as consistent monitoring metrics will be outlined in the procedures document as well. Greater and enhanced documentation will be properly maintained and available for review as required. Responsible Party: Tamara Barnes, CFO

Management Response #2022-009: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, which made it extremely difficult to find supporting documentation. Corrective Action Plan: The following action plans have since been implemented: • During the fourth quarter in 2022, finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • During the fourth quarter in 2022 a new process was implemented to track grant related activities. Prior to any drawdown, the expenses are pulled from the G/L and reviewed. The expenses are entered into a spreadsheet and totaled based on the applicable federal award which has been assigned a client ID in the accounting system. The finance team is notified of the amount due to be drawn for each federal award. That amount is entered into the accounting system as an accounts receivable entry. This process has been formally documented. • Project Budget Reports have been created for each federal award. These reports include the budget, expenses for each month and the revenue (drawdown) incurred for each month. The reports will be reviewed and reconciled by the grants administration staff and finance monthly to ensure all agree with the allocated costs and costs and are in compliance with grant regulations. Once approved by both teams the reports will be routed for signatures. This process was launched in July 2022. • Supporting documentation for all draws will be maintained on a shared network drive so that an adequate audit trail will be established. This drive will be backed up on a regular basis by the Information Technology team. Responsible Party: Tamara Barnes, CFO

Management Response #2022-006: Due to turnover of several key financial executives and personnel, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Corrective Action Plan: Due to the staff turnover and shortage in 2020-2021, this process was not consistently maintained or documented. The following action items have been or will be taken: • In 2022, finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • The grants finance department will also create actual to budget reports in accordance with HRSA guidelines for fringe costs. • The report will be reconciled monthly based on fringe costs allowed by the grant as it relates to the employee class such as part time or providers that may have additional benefits. Adjustments will be recorded in the GL (General Ledger) accordingly. Responsible Party: Tamara Barnes, CFO

Management Response #2022-005: The time keeping system and process does not currently allow tracking of time based on funded resources. The past practice had been for the finance department manually calculated salary allocations but due to staff turnover in FY2021-22, the process was not consistently followed. Corrective Action Plan: The following action items have been or will be taken: • In 2022, the finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • Monthly time and effort reports to include recorded time worked under each grant will be sent to the employee and require employee and supervisor approval. • As of 2022 salary/wages are allocated to federal grants based on actual costs received from payroll. • Finance Management will also create actual to budget reports in accordance with HRSA (Health Resources and Services Administration) guidelines for salaries/wages and hours. The report will be reconciled monthly. • Human Resources department will collaborate with the Grants and Finance teams to ensure grants hours is added as an option within the timekeeping system for accurate recording for FY24. Responsible Party: Tamara Barnes, CFO

Responsible: Thomas Hoover, CFO Corrective Actions: Update Finance policies to specify that documentation of review and approval of both the costs charged and the allocation methods of costs charged to federal grants be maintained. Completion Date: March 29, 2023 Explanation: Policies have been in place over the coding of costs allocated to federal grants in compliance with CFR 200 and were enhanced in 2023 in response to an OJJDP/OCFO recommendation. Review and approval of costs after being approved by an authorized signer takes place in multiple steps and concludes with preparation of reimbursements and financial grant reports (FFR). In order to further demonstrate compliance as recommended, Management has updated Finance policies to capture the documentation and maintenance of such documentation of Supervisory review and approval.

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to document and maintain the documentation of Supervisory review and approval of journal entries charging payroll costs to federal grants; 2) Update Finance policies to review estimates of accrued costs charged to federal grants at calendar/fiscal year end to determine whether true-ups to actual costs are necessary. Completion Date: March 29, 2023 Explanation: 1) Review of allocated payroll costs: Payroll processing and recording of costs charged to federal grants has in practice, consistently involved multiple review and approval steps by at least two employees. Detailed records of these steps are maintained in Finance records for each payroll, including the allocated grant costs. However, Management acknowledges that an additional step be added to capture the documentation of review and approval of the payroll journal entries that allocate payroll costs to federal grants. This step was put in place in 2023 to resolve a recommendation from OJJDP/OCFO. Supervisor review and approval is captured directly in the general ledger system. Finance policies have been updated to codify this additional step as recommended. 2) Procedure for trueing up estimates: Three of sixty transactions tested showed that payroll costs were accrued at year end based on the approved grant budget but were not trued up in the new accounting period based on actual costs. The total variance of the three transactions was $6.20. Finance policies have been updated to include evaluating year-end accruals to determine whether a true-up is necessary in the new period as recommended.

All future federal expenditures will be reconciled to the disbursement ledger.

Finding No. 2022-003; Supportive Housing for the Elderly (Section 202), CFDA 14.157 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended November 30, 2022, the project paid expenses in the amount of $326,282 on behalf of other affiliates from project cash without HUD approval. The amount due to the project as of November 30, 2022 is $326,282. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $326,282 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $326,282 Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: B – Allowable Costs/Cost Principles Views of Responsible Officials and Planned Corrective Actions Because the PRAC renewals were so delayed, therefore there was no money available to pay back the project. Furthermore, the insurance costs are tremendous and had to be financed. In order to ensure the payments are applied and paid timely it is best to have the entire amount pulled from one bank account. If each entity were to pay its share it would cause confusion and may result in possible cancellation. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates.

Finding 2022-002 Unauthorized loans from project assets Comments on the Finding and Each Recommendation Statement of Condition During the year ended September 30, 2022, the project paid expenses in the amount of $81,886 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2022 is $81,886. Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $81,886 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $ 81,886. Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code B – Allowable Cost/Costs Principles Reporting Views of Responsible Officials The Corporation agrees with the finding and the auditor's recommendations have been adopted. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates..

2- Finding No. 2022-002; Unauthorized loans from project assets Statement of Condition During the year ended September 30, 2022, the project paid expenses in the amount of $32,736 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2022 is $32,736. Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to approved project operating costs. Effect or Potential Effect The payments of $32,736 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $32,736. Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code B – Allowable Cost/Costs Principles Reporting Views of Responsible Officials The Corporation agrees with the finding and the auditor's recommendations have been adopted. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates.

The Management Agent will properly review all statement of financial position and statement of activity accounts to determine no material misstatements every month.

Corrective action plan over control environment over lost revenue COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s procedures for calculating lost revenues for the purposes of PRF reporting should be designed to ensure that audited year end numbers are reported and/or tied back to amounts that are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: As of July 2024, there is no further lost revenue reporting that is required to be reported. Management will implement more robust internal controls in preparation for similar future grant reporting. For lost revenues that have been submitted for PRF that do not tie back to an audited financial statement, a reconciliation will be completed and documented. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 703-629-8155 Planned completion date for corrective action plan: July 31, 2024 and going forward.

Timely Preparation of Schedule of Expenditures of Federal Awards (SEFA) COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s policy and procedure should be designed to ensure timely reporting as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will enhance its procedures around the preparation of the SEFA to include a timely year-end reconciliation between the general ledger and all source documentation to ensure that all Federal expenditures are complete and accurately reported in the SEFA in fiscal 2024. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 703-629-8155 Planned completion date for corrective action plan: For the creation of the Schedule for FY2023.

TINDLEY ACTION PLAN 1. Develop and implement Procurement Policy (completed and on-going by CFO/Accounting Manager/Accountant/Grants Manager/Network President/Department Heads) a. Enhance written procedures for procurement and accounts payable. i. Purchases between $15,000-$25,000 will require two quotes for all new vendors; purchases between $25,000-$75,000 will require three quotes for all vendors; and purchases over $75,000 will require a competitive bid process for all vendors. ii. Establish a Master Vendor list. 1. Master Vendors may be used for up to $20,000 for regular services and products in the normal course of business with dual approval by the Network President and CFO. b. Require vendor bids/quotes for services. c. Segregate purchasing duties. 2. Research new vendors prior to utilization (implemented and ongoing by CFO/Accountant) a. Are these vendors commonly known in the industry or the community? b. Does the vendor have a valid website, phone number, address and email address? 3. Conduct Periodic/Continuous Fraud-Detection Monitoring (CFO – at every fiscal year end) a. Annually identify (1) Tindley’s top 20 vendors, (2) all Tindley vendors receiving annual payments totaling more than $10,000, and (3) any new vendors receiving annual payments totaling more than $5,000. i. Ensure there are valid and updated contracts for these vendors. ii. Ensure the description for services on the corresponding. invoices are detailed and complete. iii. Assess multiple corresponding invoices that have the same total amounts. 4. Refine and codify job descriptions/job duties for Network President, CFO, Grants & Compliance Manager, and Director of Development (HR/Board to be completed by 9/30/24) a. Keep these job descriptions in a database to ensure a smooth transition in the event of a departure or retirement. b. The job descriptions should highlight the financial compliance aspects of each position. 5. Change reporting structure for CFO (to be implemented by HR/Board 9/30/24) a. CFO will report directly to the Board with a dotted line to the Network President. 6. Provide anti-fraud training for Network President, CFO, Director of Development, Grants & Compliance Manager, and in-house accounting professionals (to be implemented by Network President/CFO and completed by 11/30/24) 7. Establish a Whistleblower/Ethics hotline to report suspected fraud (to be implemented by HR 9/30/24) a. Ensure employees understand that it is available to report suspected fraud. b. Develop procedures for responding to whistleblower allegations. PROCUREMENT POLICIES AND PROCEDURES I. INTRODUCTION AND PURPOSE Tindley should adhere to strict ethical and legal standards to prevent fraud and ensure accountability. This procurement policy should be cross-referenced with current local, state, and federal laws. II. CODE OF CONDUCT A. Conflict of Interest Tindley purchasers shall not participate in the selection, award, or administration of a contract if they have a real or apparent conflict of interest. Such a conflict arises when the Tindley purchaser; any immediate family member (spouse, child, parent, parent in law, sibling, or sibling in law); partner; or an organization that employs, or is about to employ, any of the above has a direct or indirect financial or other interest in, or will receive a tangible personal benefit from, a firm or individual considered for the contract award. An “organizational conflict of interest” is created because of a relationship that a Tindley employee has with a parent, affiliate, or subsidiary organization that is involved in the transaction such that the Tindley employee is or appears to be unable to be impartial in conducting a procurement action involving the related organization. B. Gifts, Money, Gratuities Tindley employees involved in the purchasing process shall not solicit or accept gifts, money, gratuities, favors, or anything of monetary value, except unsolicited items or services of nominal value from vendors, prospective vendors, parties to subcontracts, or any other person or entity that receives, or may receive compensation for providing goods or performing services to Tindley. All Tindley purchasers shall review and comply with Tindley’s procedures for disclosing, reviewing, and addressing actual and potential conflicts of interest. III. PROCUREMENT PROCEDURES A. Procurement Procedure See chart at the end of document B. Bid Procedures All procurement shall be conducted in a manner that provides, to the maximum extent practical, a full and open competition. Tindley bid procedures should always follow local, state, and federal requirements. Procurement Processes should include the following: 1. Assemble a Procurement Committee consisting of the Network President, CFO, Grant Manager, and the requestor of the product or service. i. In the event that the requestor of the product or service is the Network President, a Tindley Board member of the applicable committee that corresponds to the request will be asked to participate. 2. Pre-Bid Phase. i. If an outside vendor is needed to develop the bid specifications for a bid project, the vendor, or related parties to the vendor cannot participate in the bid. ii. The procurement committee should have specific criteria of the bid specifications including how bids will be judged based on price, quality, experience of vendors, etc. iii. All solicitations shall incorporate a clear and accurate description of the technical requirements for products or services to be procured. iv. Identify all requirements which offerors must fulfill and all other factors to be used in evaluating bids and proposals. v. If required by local, state, and or federal laws, Tindley should publicly announce in advance of projects that require a competitive bid process. vi. Vendors should not be allowed to interface with Tindley procurement committee members before any public bids are announced, and post-bid announcement, interactions should occur only as part of the formal bid process (questions and answers in writing, face-to-face walk-throughs, proposal phases, and actual bid submissions). 3. Bid Phase. i. All bidders should have adequate time to respond to a bid, including Q&A sessions, and a face-to-face walk-through if necessary. ii. The Tindley employee sending out bid packages including specifications, should not be the same person receiving the vendor bid submissions. iii. The Tindley employee receiving the bid submissions should time and date stamp each bid received and the committee should exclude any bids submitted after the bid deadline. iv. Tindley employees are forbidden to disclose to vendors information about other bidders, including bid proposal contents such as pricing. 4. Bid Selection Phase. i. The procurement committee should develop a bid template and checklist that ranks bids based on criteria developed by the committee and ensures bid procedures are followed. ii. If the procurement committee chooses the winning bid on criteria other than what is stated in the original specifications, the committee must document the reasons why. For example, if the winning bid was not the lowest price, the committee must justify in writing why the vendor was selected. C. Competition All procurement shall be conducted in a manner that provides, to the maximum extent practical, a full and open competition. 1. Procurements shall avoid noncompetitive practices that may restrict or eliminate competition, including but not limited to: a. Unreasonable qualification requirements. b. Unnecessary experience and excessive bonding requirements. c. Non-competitive pricing practices between firms or affiliated companies. d. Non-competitive contracts to consultants on retainer contracts e. Organizational conflicts of interest. f. Specifying “brand name” only instead of allowing “an equal to product.” 2. Procurements shall not intentionally split a single purchase into two or more separate purchases to avoid dollar thresholds that require more formal procurement methods. 3. Procurements shall include in any pre-qualified list an adequate number of current qualified vendors firms or products. 4. Procurements shall not preclude potential bidders from qualifying during the solicitation period. 5. Procurements shall not use any geographic preferences (state local or tribal) in the evaluation of bid proposals except where expressly mandated or encouraged by applicable federal statutes. 6. The procurement team must find, when possible, bidders to compete that were not provided by the Tindley requester. 7. The procurement committee must use independent judgment and notify the Board of Directors and ethics hotline if the requester of products or services is attempting to use undue influence for the team to select specific vendors. D. Considerations Tindley purchasers should take the following actions when procuring goods and services. 1. Conduct a lease versus purchase analysis when appropriate, including for property and large equipment. 2. Consolidate or break out procurements to obtain a more economical purchase if possible. 3. Use state and local intergovernmental or inter-entity agreements, or common or shared goods and services, where appropriate. 4. Use federal excess and surplus property in lieu of purchasing new equipment and property if it is feasible and reduces project costs. 5. Use time and materials contracts only if no other contract is suitable and the contract includes a ceiling price that the contractor exceeds at their own risk. If such a contract is negotiated and awarded, Tindley must assert a high degree of oversight to obtain reasonable assurance that the contractor is using efficient methods and effective cost controls. IV. PROCUREMENT METHODS A. All procurements made under this policy shall: 1. Be necessary, at a reasonable cost, documented, not prohibited by law or the applicable funding source, and made in accordance with this policy. 2. Avoid acquiring unnecessary or duplicative items. 3. Engage responsible vendors who possess the ability to perform successfully under the terms and conditions of a proposed procurement. 4. Tindley purchasers shall consider vendor integrity, public policy compliance, past performance record, and financial and technical resources. B. Procurement Parameters For all transactions, Tindley shall follow the applicable procurement method set forth in Appendix 1 C. Exceptions to Standards Methods Solicitation of a proposal from a single source may only be used if the following apply and are documented: 1. The item is only available from single source. 2. Public exigency or emergency will not permit any delay. 3. The Federal awarding agency or pass-through expressly authorizes the sole source in response to a Tindley request. 4. After soliciting a number of sources, competition is determined inadequate. V. DOCUMENTATION A. Records Tindley shall maintain records sufficient to detail the history of each procurement transaction. These records must include, but are not limited to: 1. A description and supporting documentation showing the rationale for the procurement method (e.g., cost estimates). 2. Selection of contract type. 3. Written price or rate quotations (such as catalog price, online price, e-mail or written quote), if applicable. 4. Copies of advertisements, requests for proposals, bid sheets or bid proposal packets. 5. Reasons for vendor selection or rejection, including Finance Committee and Board Minutes, rejection letters, and award letters. 6. And the basis for the contract price. VI. COMPLIANCE WITH THIS POLICY Program directors and, where applicable, the purchasing committee, shall maintain oversight to ensure that contractors and vendors perform in accordance with the terms, conditions, and specifications of contracts or purchase orders. Violations of this policy may result in disciplinary action, up to and including termination. VII. VENDOR SELECTION CRITERIA For vendors that have been selected in a competitive bid or that will provide critical services to the school, Tindley should evaluate them based on cost, quality, past performance, experience, and financial stability. Before providing services or products, the selected vendor can be asked to provide references, allow for background checks, and provide documentation such as certificate of insurance, certificate standing, adherence to anti-fraud policies, and contracts with right-toaudit clauses.

While discussing this issue with the USDA over email it was agreed that other expenses that were previously paid by the district and not covered by the USDA loan would be acceptable to use instead of the miscalculated, overage of the interest expense. The district had spent several hundred thousand dollars in funds above the originally budgeted district contribution towards the Water Storage Tank Project previous to acquiring the loan with the USDA.

CONDITION: The District did not maintain a general ledger system of accounting for its Cafeteria Fund which reports the financial activity of the federal National School Lunch and School Breakfast Programs. The financial activity occurring in this Fund is maintained in checkbook fashion during the fiscal year. This is a repeat finding (2021-004) from the previous fiscal year. CRITERIA: Prudent internal control over accounting for federal program funds requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the receipt and use of federal funds as stated in Section 2 CFR Part 200 of the Uniform Guidance. Best practices suggest that the use of a general ledger system of accounting would enable the District to aggregate financial information involving federal funds during the fiscal year in such a manner to properly manage, monitor, and report the financial activity in compliance with federal program guidelines. RECOMMENDATION: The District’s accounting software can readily account for the financial activity of all Funds in a manner like the District’s General Fund. I am recommending that the management of the School District utilize the accounting software to enter the financial activity (Receipts and Disbursements) of the Cafeteria Fund in a manner like the General Fund. This procedure will significantly enhance the District-wide internal controls over financial reporting for the Cafeteria Fund, as well as provide management the ability to produce meaningful financial reports reflecting the activity in the Cafeteria Fund for prudent oversight by the Board of Education. In addition, this procedure will enable the District to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200 of the Uniform Guidance. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is reviewing its current system of processing the transactions for the Cafeteria Fund to determine the most efficient and effective manner for implementation of a general ledger system of accounting for this Fund as opposed to its current manual process. It is anticipated that the conversion of this Fund into the District’s accounting software can be completed during the 2024-2025 fiscal year to enable the District to comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance.

CONDITION: During my sample review of the District’s completion of its federal grant program ‘Quarterly Cash On Hand Reconciliations’ for the 2021-2022 4th fiscal quarter for the ESSER II and ARP ESSER grants, I noted that the amounts reported to date for ‘total disbursements’ could not be ascertained from the coding of these expenditures in the District’s general ledger (See Finding 2022-005) and did not reconcile to the separate spreadsheets maintained by the School District. This is a repeat finding (2021-006) from the previous fiscal year. CRITERIA: Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance, to allow for the proper completion of the ‘quarterly cash on hand reconciliations’. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is in the process of revising its chart of accounts in the general ledger to properly reflect the funding source codes for federal program expenditures, and other available funding source codes (state and local) as applicable to the District. It is anticipated that the updated chart of accounts will be utilized by the District starting with the 2024-2025 fiscal year to enable the District to effectively access the necessary federal expenditure totals, by individual grant program, to document and support amounts reported as ‘total cash disbursed’ on the quarterly cash on hand reconciliations. This procedure will enable the District to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations.

CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2021-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is in the process of revising its chart of accounts in the general ledger to properly reflect the funding source codes for federal program expenditures, and other available funding source codes (state and local) as applicable to the District. It is anticipated that the updated chart of accounts will be utilized by the District starting with the 2024-2025 fiscal year to enable the District to enhance its internal controls for tracking and monitoring federal program expenditures and to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations.

U.S. Department of Agriculture Iron County Hospital District dba: Iron County Medical Center (“Medical Center”) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 – June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022 – 2023 Community Facilities Loans and Grants Recommendation: We recommend the Hospital design controls to ensure that reporting is completing in accordance with latest USDA guidelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Medical Center will ensure that controls are put into place to ensure timely reporting in accordance with the USDA guidelines. Name of the contact person responsible for corrective action: Steve Weiss, Interim CFO Planned completion date for corrective action plan: July 1, 2022

On the 15th of each month the Residential Division Director will meet with the Director of Finance to review the prior months match and year to date match and sign off on the report. This will assist in ensuring all match (cash/inkind) are accounted for accurately and that MHACG meets the required 25% match.

Corrective Action Plan for Fiscal Year Ended June 30, 2022 Finding 2022-001 Condition The District did not meet the deadline for submission of its data collection form and reporting package to the Federal Audit Clearinghouse for the fiscal year ended June 30, 2021. The data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors? report or nine months after the end of the audit period. Therefore, the deadline for submission of the required information for the fiscal year ended June 30, 2021, was December 22, 2021. The data collection form and reporting package was not submitted by that date. Corrective Action Plan Corrective Action Planned: Establish procedures to verify that the data collection form and reporting package have been properly submitted on a timely basis. Name of Contact Person Responsible for Corrective Action: Matthew Moore, CPA, Chief Financial Officer Anticipated Completion Date: December 16, 2022

Finding: 2022-001 - Earmarking, Reporting (Performance Progress Reporting) – Material Weakness in Internal Controls Over Compliance and Instance of Noncompliance (Scope Limitation) Recommendation: We recommend that the Coalition develop policies and procedures for tracking actual expenditures related to earmarking requirements and maintain all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual performance progress reports. Corrective Action Plan: The Coalition’s staff has developed policies and procedures for tracking actual expenditures related to these requirements, and maintaining all supporting documentation for the calculation of the earmarking percentages that are reported in the semi-annual progress reports. The Coalition has developed an internal control process for reviewing and approving calculations required by Section 50 of the grant agreement and has strengthened its reporting management review controls to ensure that the review is effective to ensure the completeness and accuracy of reports, and that all elements are appropriately supported, prior to submission the federal agency. Anticipated Completion: Late Summer and Fall of 2023 Responsible Party: WCADVSA Co-Directors, Tiffany Eskelson-Maestas and Susie Markus

2022-012 Housing Voucher Cluster – Assistance Listing Nos. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that recertifications are uploaded to PIC in accordance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: The HCVP shall recruit and hire a dedicated Data Analyst to oversee the PIC entries and to ensure that recertifications are uploaded in accordance with reporting requirements. The PIC uploads will be quality-controlled monthly by HCVP and quarterly by the OAC. Name of the contact person responsible for corrective action: Khaliah Payne. Planned completion date for corrective action plan: 9/30/24.