Corrective Action Plans

The YWCA will ensure that all federal award reports are filed in a timely manner. The YWCA is in the process of posting a new position, Director of Grants and Compliance. The individual in this new role will be responsible for tracking report due dates and working with the individuals responsible for the content of these reports to ensure the information is accurate and on time. In situations where the Director of Grants and Compliance is responsible for gathering the data for required reporting, the data will be reviewed by either the CFO or CEO prior to submission of the report.

The YWCA will implement the following changes in its accounting procedures: 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.

2023-001 Title X – Assistance Listing No. 93.217 Recommendation: We recommend management develop procedures to ensure the required reporting submitted to the funder is complete and accurate. Additionally, systems should be put in place to both track and report its progress on the non-federal share requirement and any program income. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PPNCS has initiated a review process to ensure the reporting is complete and accurate per the Federal Financial Report Instructions prior to submission. Name of the contact person responsible for corrective action: Randy Drager, CFO Planned completion date for corrective action plan: April 1, 2024

2023-002 Provider Relief Fund Reporting of Lost Revenue Corrective action planned: Reporting schedule will be corrected as indicated to ensure lost revenue calculation is correct. Anticipated completion date: June 30, 2024 Contact person responsible for corrective action: David Usher, Chief Financial Officer

2023-001 Policies and Procedures for Federal Awards Corrective action planned: Policies and procedures for the tracking and usage of federal funds will be written and run through the appropriate approval process to be added to the facilities Policy Manual. Anticipated completion date: June 30, 2024 Contact person responsible for corrective action: David Usher, Chief Financial Officer

FINDING 2023 – 004: ALLOWABLE ACTIVITIES HOUSING CHOICE VOUCHER – 14.871 MATERIAL WEAKNESS / NON-COMPLIANCE – ACTIVITIES ALLOWED OR UNALLOWED QUESTIONED COSTS: $4,808.90 The Agency agrees with the above finding. FY 2022-2023 was a year of transition for Goldenrod Regional Housing Agency with the movement of staff into the Interim Director position from a position of case management. The director acknowledges inexperience in accounting procedures noting additional training is needed. Utilizing a single general ledger to account for all the Agency’s activities, while not comingled, does not allow the Agency to monitor each program separately. The Agency has contacted our fee accountant regarding the auditor’s recommendation to generate a new income statement or have separate general ledgers maintained for each program to note the financial condition of each program and make the needed adjustments. Further exploration is needed to determine how to repay the Voucher Program for the Management overage.

COVID-19 Emergency Rental Assistance – Assistance Listing Number 21.023 Recommendation: We recommend the Authority implements an internal control over compliance to evidence the expenses are approved to be charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Monthly reports are provided for Cost Distribution by Deputy Director of Financial Operations to Deputy Director Programs for review of appropriate charging. Corrections are provided back to Finance and made in the financial system. Name(s) of the contact person(s) responsible for corrective action: Ellen Eudy, Deputy Director, Financial Operations and Marni Holloway, Deputy Director, Programs Planned completion date for corrective action plan: June 30, 2024

COVID-19 Emergency Rental Assistance – Assistance Listing Number 21.023 Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained to support amounts reported. Review and approval of the amounts reported to Treasury should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: SC Housing is in the process of data transfer and will have direct access to review data and provide reports supporting entry in to the Treasury Portal. Name(s) of the contact person(s) responsible for corrective action: Gina Connelly, Emergency Housing Manager (with GuideHouse), Marni Holloway, Deputy Director of Programs Planned completion date for corrective action plan: Implementing and will be ongoing through the sunset dates of each program.

Housing Voucher Cluster – Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All initial lease-ups, other change of units, and rent increases are reviewed by the Director of HVCP Operations for confirm that rent reasonableness was performed prior to the effective date of the application action. Name(s) of the contact person(s) responsible for corrective action: Lenzy Morris, HCVP Director of Operations. Planned completion date for corrective action plan: Currently implemented and ongoing.

Housing Voucher Cluster – Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Monthly Failed Item Report Review: • Director of Operations is generating and reviewing a monthly failed HQS inspection report o Have units been re-inspected? o If not, why? o Prompt abatement action immediately, if necessary ▪ Management will issue written authorization to abate within the HUD required timeframe Reinspection letter o Staff required to monitor 24-hour correction time frame and move to abate subsidy for those that remain non-compliance without reasonable justification/documentation of repair ▪ Requests for extensions on 24-hour cures will not be granted o Deficiencies which provide a 30-day cure period are monitored and re-inspected within the allowed 30-day window, unless satisfactory proof of cure has been submitted prior to this time ▪ Reasonable written requests for extensions may be granted if it is determined that the owner has made a good faith effort to remedy identified issues but are unable to meet the 30-day time frame due to reasons beyond their control o Will be reviewed by senior management to determine abatements required Name(s) of the contact person(s) responsible for corrective action: Lenzy Morris, HCVP Director of Operations and Lisa T. Wilkerson, Director of Rental Assistance and Compliance Planned completion date for corrective action plan: Currently implemented and ongoing.

Housing Voucher Cluster – Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that required HQS and QC inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Periodic HQS Inspections: Procedures are in place that require staff to generate a listing of all properties requiring inspection between ninety to one hundred and twenty days prior to the scheduled inspection date. Each unit under HAP contract must be inspected prior to execution of the initial lease and prior to execution of the HAPcontract and no less than biennially per our HUD-approved Administrative Plan (not annually) thereafter to confirm the unit continues to meet minimum HUD requirements. This report is generated a minimum of once monthly to assist with scheduling. The report and scheduling of inspections is monitored by the Director of Housing Choice Voucher Operations. Procedures have been updated to require that the Director of Rental Assistance and Compliance review all inspections completed after the date due and the accompanying explanation for the delay. Acceptable reasons for delay should be validated as beyond Authority control and documented accordingly. Management will track and analyze the data generated from the late inspections to identify patterns and implement additional corrective actions as warranted. QC Inspections: As of March 28, 2024, all 2024 fiscal year QC inspections have been completed. Ongoing, all required inspections will be completed no later than the end of each fiscal year. A status report documenting all efforts and results will be submitted monthly to the Director of Rental Assistance and Compliance. Management will track and analyze the data generated from these inspections to assure all program inspections are consistent and compliant and that any patterns identified are effectively addressed with additional training, etc. as warranted. Note: As of March 26, 2023, the HCVP is undergoing a minor departmental restructure, final effective date is undetermined at this time however, all parties are actively engaged in implementing the approved changes. One of the modifications includes the designation of one particular senior inspector as the official QC inspection team lead. The designation of this individual as the project lead will assure that QC inspections will be completed timely and in compliance with regulatory requirements. Name(s) of the contact person(s) responsible for corrective action: Wallace Preston, Training/HQS QC Manager, Lenzy Morris, HCVP Director of Operations and Lisa T. Wilkerson, Director of Rental Assistance and Compliance Planned completion date for corrective action plan: On track to demonstrate compliance with fiscal year ending June 30, 2024 and each fiscal year thereafter.

View of Responsible Officials and Planned Corrective Actions: The Organization is committed to properly tracking and allocating Federal expenditures. The Organization has created adequate internal control processes to ensure expenses are allocated correctly and in accordance with the requirements of the Uniform Guidance.

Unlike other subgrants managed by the Department of Law and Public Safety (DLPS), the subgrants in the Public Assistance program are not issued by the Department but instead are issued by the Federal Emergency Management Agency (FEMA). These FEMA-issued subgrants take the form of Project Worksheets (PWs) and are directly related to a specific disaster. FEMA informs the DLPS of the approved PWs after they are issued. Given the unique nature of the PW issuance, the DLPS is not in a position to report on the FFATA Subaward Reporting System (FSRS) at the time PWs are issued. This contrasts with other grant programs overseen by the DLPS, which do allow for timely subaward reporting in FSRS. The Department will continue to work with our FEMA partners, incorporating any guidance they provide, to develop procedures that ensure subawards are reported in FSRS within the FFATA reporting requirements. COMPLETION DATE/ CONTACT PERSON & PHONE# Fiscal Year 2024 and Ongoing Salvatore Marcello (609) 882-2000 ext.3046 Salvatore.Marcello@njsp.gov

The Department of Human Services’ Division of Family Development (DFD) agrees with the audit finding regarding the required submission of subawards to the FFATA Subaward Reporting System (FSRS). Due to the complexity and time required to compile and report FFATA subaward data, the DFD is in the process of creating a new full-time equivalent position (FTE) for this required federal reporting task. In accordance with the finding recommendation, the DFD will develop internal controls and procedures to ensure the timely reporting of all required subawards to FSRS. An initial review of the FSRS by DFD fiscal staff appeared to indicate that some federal grant award data that should be prepopulated by the awarding federal agency and available on the website was missing (e.g. Child Care M&M available; Discretionary not found). Staff will reach out to the necessary federal agencies to communicate instances of missing federal award information in an effort to ensure that the DFD has the ability to input the required subaward information. DFD anticipates that the assessment and development of policy and procedures related to this task will take approximately three (3) months. Staff assignment, training, and submission of federal grant subaward information to the federal website will occur over the next state fiscal year. COMPLETION DATE/ CONTACT PERSON Policy Completion Date: June 30, 2024 Implementation Date: Fiscal Year 2025 Thomas Mattaliano, CFO-DFD (609) 588-3370 Thomas.Mattaliano@dhs.nj.gov

The Department of Community Affairs (DCA) has recently implemented timely reporting of required FFATA subaward data in the Federal Subaward Reporting System (FSRS). The FFATA reporting process is fully documented, and additional staff have been hired and trained on the process to further support the federal reporting functions. The FFATA reports identified by the auditors with inaccurate subaward amounts reported have also been corrected in FSRS. COMPLETION DATE/ CONTACT PERSON April 30, 2024 Fidel Ekhelar (609) 815-3905 Fidel.Ekhelar@dca.nj.gov

The Department of Human Services’ Division of Family Development (DFD) agrees with the audit finding regarding the required submission of subawards to the FFATA Subaward Reporting System (FSRS). Due to the complexity and time required to compile and report FFATA subaward data, the DFD is in the process of creating a new full-time equivalent position (FTE) for this required federal reporting task. In accordance with the finding recommendation, the DFD will develop internal controls and procedures to ensure the timely reporting of all required subawards to FSRS. An initial review of the FSRS by DFD fiscal staff appeared to indicate that some federal grant award data that should be prepopulated by the awarding federal agency and available on the website was missing (e.g. Child Care M&M available; Discretionary not found). Staff will reach out to the necessary federal agencies to communicate instances of missing federal award information in an effort to ensure that the DFD has the ability to input the required subaward information. DFD anticipates that the assessment and development of policy and procedures related to this task will take approximately three (3) months. Staff assignment, training, and submission of federal grant subaward information to the federal website will occur over the next state fiscal year. COMPLETION DATE/ CONTACT PERSON Policy Completion Date: June 30, 2024 Implementation Date: Fiscal Year 2025 Thomas Mattaliano, CFO-DFD (609) 588-3370 Thomas.Mattaliano@dhs.nj.gov

Based on the Corrective Action Plan (CAP) developed for the prior year FY 2022 audit finding cited for FFATA reporting, the Department of Health (DOH) Grants Unit, with coordination from the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) fiscal staff, added a new function to the System for Administering Grants Electronically (SAGE) that pulls all subaward data for the ELC program using the program’s 93.323 federal Assistance Listing Number (ALN). Thus, the CAP implemented in September 2022 for the prior year FY 2022 audit finding includes SAGE now pulling the subaward data for the entire ELC program by the ALN number and enables the ELC fiscal staff to access all ELC subawards within the DOH. ELC fiscal staff also has a task reminder set to report at the end of each month, enter subaward information into the FFATA Subaward Reporting System (FSRS), and upload each report submitted to the SharePoint ELC Document Library at the end of each month. As per the original CAP created under the FY 2022 audit, FFATA information for ELC subawards were entered into FSRS beginning on September 1, 2022 and DOH actions and efforts have continued to ensure compliance going forward. COMPLETION DATE/ CONTACT PERSON April 10, 2024 Rina Warehall (609) 913-5300 Rina.Warehall@doh.nj.gov

The Department of Health’s (DOH) Vaccine Preventable Disease Program (VPDP) is in compliance with the Federal Funding Accountability and Transparency Act (FFATA) requirements with regard to reporting all active first-tier subawards of federal COVID-19 funds that DOH divisions have issued totaling $30,000 or greater under this Cooperative Agreement and COVID-19 Supplemental. However, it is not in compliance with regard to reporting required subaward data in FSRS by the end of the month following the month in which DOH has made the subawards totaling $30,000 or greater. The VPDP will continue to follow the DOH policy set forth in FMC 22-05 and report to FSRS all active first-tier subawards of federal COVID-19 funds DOH divisions have issued at $30,000 or greater under the COVID-19 Supplementals. The VPDP fiscal/grants leadership team will strive to ensure each of the identified subawards is entered on the FFATA Subaward Reporting System (FSRS) website by the end of the month following the month that DOH has made the subawards. VPDP will continue its efforts to bring the gap in reporting to FSRS down from five months presently to within the specified FFATA submission deadlines denoted above. VPDP also has on boarded a full-time Contract Administrator 2 who will be responsible for reporting FFATA data into FSRS for the Immunization Cooperative Agreement. COMPLETION DATE/ CONTACT PERSON April 4, 2024 Susan Barcarola (609) 943-5302 Susan.Barcarola1@doh.nj.gov

The New Jersey Department of Education (NJDOE) Office of Grants Management (OGM) understands the need to be compliant with FFATA reporting in accordance with the Uniform Guidance. Internal controls and processes are in place to ensure NJDOE’s FFATA reporting process is working efficiently and timely. This noncompliance finding is not due to a lack of controls within NJDOE but lies squarely on system issues at SAM.gov and the FFATA Subaward Reporting System (FSRS) sites and until the issues listed below are corrected on these federal system sites, NJDOE will continue to be noncompliant with timely FFATA reporting. Issues with the SAM.gov and FSRS sites: • SAM.gov has approved NJDOE’s local education agency (LEA) registrations without a ZIP+4, but FSRS reporting system for FFATA uploads requires ZIP+4 for each LEA. The two systems use the same database, which means information registered on SAM.gov feeds directly into the FSRS system. However, because FSRS batch uploads require a ZIP+4, those LEAs that were approved by SAM.gov without a ZIP+4 during the registration process, are rejected from the FFATA report batch upload. There is an option to manually load each LEA and their details into the system, but the process becomes incredibly time consuming, given the 700+ LEAs in the state, the number of federal awards granted, and the steps for identifying & removing rejected LEAs from the batch upload. • Issues NJDOE has with SAM.gov and FSRS have been shared with the federal helpdesk and a USED representative without avail, as the systematic issue remains unresolved and continues to delay our FFATA reporting process. • There are several rural LEAs in the state that do not have a ZIP+4. These LEAs will continue to be rejected from the batch upload, delaying our FFATA reporting process, if SAM.gov and FSRS do not come up with a viable solution. • There were a number of LEAs that were continuously rejected from the upload by FSRS for no obvious reasons. The error message received was the same exact error we receive for incorrect zip codes. After spending much time investigating the cause with the helpdesk support, it was identified that FSRS did not update their system to reflect the Congressional District code changes during New Jersey’s redistricting process. • The FSRS system rejects batch uploads if a single lower-case SAM UEIs is entered in the batch file. However, SAM.gov search box and the FSRS manual uploads are not case sensitive. Batch uploads are the only place where SAM UEIs are case sensitive. Further, this information is not included in any of the FSRS User Guides or manuals. I have shared this with the FSRS helpdesk, but no solution was provided. Again, this discrepancy in their system affects and delays our FFATA reporting processes. NJDOE dedicated personnel, including the director of OGM, continuously work with SAM.gov, FSRS system, and both system sites’ help desks, to bring to light the issues mentioned above in order to express the urgent need for corrective actions at the federal system sites to allow for timely FFATA reporting. In addition internal controls and procedures are in place at NJDOE related to FFATA reporting and corrective actions are constantly performed in real time to perform the below NJDOE Internal Controls and Procedures. Some of these procedures include reviewing internal SAM applications and troubleshooting with NJDOE’s local education agencies (LEAs) to correct data in the application and resubmit to the federal reporting system sites with more detail included below. NJDOE Internal Controls and Procedures: • Due to the large number of LEAs in the state (700+), each FFATA report must be submitted via batch upload, which saves an enormous amount of time it takes to input data manually for every single LEA, for every grant. To address this need and to expedite the process, our vendor has created a reporting tool that generates a FFATA batch report. • We have been contacting the federal helpdesk to address the issues on their sites and asking for support. Some of those tickets were closed without providing any support and most were not helpful. • We have created and implemented an in-house System for Award Management (SAM) application, mandatory for all of our federal grant recipients. This was done specifically for FFATA reporting purposes to ensure data in these applications are directly tied to the FFATA batch reports. • The SAM applications go through a thorough review process, where data entered by the districts is compared with the data registered with SAM.gov (applicants are required to upload a copy of their Entity Overview Record, issued by SAM.gov). • SAM applications are returned for changes whenever an applicant has entered data that is inconsistent with data on SAM.gov (i.e.. Incorrect SAM UEI, incorrect zip code, incorrect zip+4, incorrect City name). • We have asked many of our districts to contact SAM.gov and update their physical address information to include the full 9-digit zip code, which was SAM.gov reviewers’ oversight. Our school districts have commented that this process can take months. • We are communicating with our districts/applicants on a daily basis through the review summary checklist, outlining the changes that must be made, as well as by email and phone. • We have implemented an automatic messaging system, where applicants are reminded to update their SAM registration expiration date, multiple times a month leading up to their expiration date. Due to the system discrepancy in the FSRS system’s batch upload, we had to create a workaround pertaining to the district’s SAM UEIs. As stated above, SAM UEIs, in batch FFATA reports, are case sensitive while not case sensitive anywhere else in the two system sites. We have updated our instructions in NJDOE’s SAM application and have added another layer of application review, to ensure that all UEIs entered are in all capital letters. Because the federal helpdesk has ignored this discrepancy and did not resolve the issue, we are obligated to take additional steps and spend additional time on FFATA batch reports. COMPLETION DATE/ CONTACT PERSON Indeterminate – Completion based on federal implementation of fixes to SAM.gov and FSRS portal as noted in views. Martin Egan, Director NJDOE Office of Grants (609) 376-9089 Martin.Egan@doe.nj.gov

The Department of Labor and Workforce Development (DLWD) transitioned from a manual contract agreement process to a web-based grant administration system in recent years that employs the System for Administering Grants Electronically (SAGE) and IntelliGrants (IGX) applications. The DLWD FFATA Reporting Unit has access to these automated systems and monitors them on a monthly basis to identify when new subaward contracts/agreements are approved in order to report required data in the FFATA system timely. DLWD corrective actions regarding FFATA reporting are expected to be fully implemented as of June 30, 2024. COMPLETION DATE/ CONTACT PERSON June 30, 2024 Theresa Vallely (609) 984-1779 Theresa.Vallely@dol.nj.gov

The Department of Labor and Workforce Development (DLWD) will continue to review and enhance controls to ensure that BAM quality control case investigations are completed timely, that reviews are signed as required by appropriate staff, and that all required case review supporting documentation is maintained in case files. DLWD corrective actions will be completed by September 30, 2024. COMPLETION DATE/ CONTACT PERSON September 30, 2024 Theresa Vallely (609) 984-1779 Theresa.Vallely@dol.nj.gov

The Reemployment Services and Eligibility Assessments (RESEA) policy and controls presently in place at the Department of Labor and Workforce Development (DLWD) require eligibility interviews to be conducted and eligibility review forms to be completed and signed by the participant and UI program representative. DLWD implemented a new process that allows staff to electronically obtain signatures through Simpligov, beginning June 2023. This process requires that staff obtain all necessary signatures before a RESEA claimant record is completed. Supervisors are assigned to monitor this process in order to mitigate the risk associated with missing information on any single RESEA customer registration. DLWD will monitor this process to ensure that all interviews are properly documented, and forms are signed and electronically uploaded to its electronic case management system of record for future reference. During the initial rollout of this process, there were records that didn’t migrate to the case management system of record. This issue has now been addressed through training. DLWD has also developed dashboards that will assist with monitoring data entry. Monthly reviews of RESEA data entry will be conducted to identify possible errors. These RESEA process changes that will be implemented by DLWD will ensure compliance with regulatory standards and assist with maintaining the integrity of its data management process. COMPLETION DATE/ CONTACT PERSON June 30, 2023 Baden Almonor (609) 777-1042 Baden.Almonor@dol.nj.gov

The Department of Labor and Workforce Development (DLWD) has controls in place to only allow an FPUC payment to be made when an underlying Unemployment Insurance (UI) payment has also been processed. FPUC payments should not be issued to any claim without the underlying UI payment being made for the same week. The FPUC payments issued and noted as exceptions during eligibility testing will be reviewed independently by DLWD to determine if the payments issued were to eligible recipients or not. For the PUA exceptions noted during Eligibility testing, overall the DLWD issued PUA payments to over 680,000 claimants during the COVID-19 pandemic. DLWD had controls in place to require a COVID related reason to make the claim PUA eligible and the weekly PUA certification required claimants to choose a COVID related reason for why they were out of work before they could get paid. The PUA payments in question will be reviewed independently by the DLWD to determine if the payments issued under PUA were appropriate or if they should have been paid instead under the regular UI program. DLWD corrective actions related to FPUC and PUA payments were fully implemented as of September 2023. COMPLETION DATE/ CONTACT PERSON September 2023 Theresa Vallely (609) 984-1779 Theresa.Vallely@dol.nj.gov

2023-002 U.S. Department of Transportation, National Infrastructure Investments: Better Utilizing Investments to Leverage Development (BUILD) Grant Assistance Listing Number 20.933; Procurement Material Weakness in Internal Control over Compliance Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award the provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. The Port Authority’s formally documented policy pre-dates Uniform Guidance and does not include many of the necessary procurement provisions. Corrective Action Plan: An updated Procurement Policy is being drafted to meet the standards set forth in 2 CFR 200.317 to 220.237, then reviewed and approved by our Board at the next appointed board Meeting. Expected Completion Date: March 2024 Responsible Individuals: Kimbra Scott

Corrective Action Planned: The Board will comply with Title 29, U. S. Code of Federal Regulations, Part 5. Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "Davis-Bacon Act") when using COVID-19 Education Stabilization Funds to fund construction contracts in excess of $2,000. Anticipated C'onipletion Date: March 15, 2024 Contact Person(s):): Cindy W. Parker; Chief School Financial Officer; cparker@blountboe.net