Corrective Action Plans

Finding 2023-003 Deposit Collateralization Material Weakness/Non-Compliance – Special Tests and Provisions Repeat Finding 2022-03 I agree with finding The requirement of the Depository Agreement was recently brought to my attention as I was not an employee at the time of the last Audit. This correction is in the process and will be put in place as soon as possible.

Finding 2023-002 Internal Control Structure Material Weakness – Eligibility, Reporting and Special Tests and provisions Repeat Finding 2022-02 I agree with finding The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board has reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.

The Cornbelt Educational Cooperative Business Manager, Pamela Selken is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the Cooperative's business office. Staffing the office at an efficient and financially feasible level precludes the hiring of enough personnel to provide an ideal environment for the internal controls. The Administration and Advisory Board is aware of the weakness in internal controls and will continue to develop policies and procedures and provide compensating controls to reduce the risk. We will also communicate this concern with our Board of Directors. The Cornbelt Educational Cooperative did adopt an Internal Controls and Procedures policy on March 13th, 2018 that does address many of these issues, and would ask for consideration reflecting this implementation. This finding will be an ongoing process, requiring continued analysis of processes and procedures in order to minimize the risk.

Finding 2023-001 The Authority agrees with finding 2023-001 • The Authority, due to increasing interest rates, purchased several CD’s with various banks in order to maximize returns. During this process Form HUD 51999 was unintentionally omitted. o The Authority will immediately begin working with financial institutions that have Housing Choice Voucher or Public Housing finds on getting Form HUD 51999 completed. By December 31, 2023 the Authority will create an investment policy that outlines the requirements. Upon annual renewal of any investment the HUD website will be checked for updated forms.

The audits are currently in progress sequentially by fiscal year.

Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

SCDEW was unable to successfully complete and submit this audit on time to submit it to the Federal Audit Clearinghouse by March 31, 2023. This occurred as the completion of the FY21 audit was delayed due to additional auditing program requirements requested by the DOL OIG. SCDEW fully understands the failure to submit audits on time could negatively impact our federal funds or termination of federal grants with DOL. We continuously communicate with the DOL on the status of this audit and other audits to keep them informed on our progress. SCDEW has missed the March 31st submission deadlines for the 2023 and 2024 agency financial audits. The agency has begun working on the 2023 agency audit and has done some work on the 2024 agency audit. SCDEW will miss the March 31st submission deadline for the 2025 agency financial audit as work on this audit has not commenced. Although these specific reporting deadlines have been missed, SCDEW constantly monitors and consistently adheres to agency wide reporting deadlines on the master reporting database. This is explained more in the paragraph below. The Agency’s contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was August 28, 2025.

SCDEW implemented a corrective action plan in response to this funding for the year ended June 30,2021, in response to similar findings in prior year audits. The SCDEW Enterprise and Project Management Office (EPMO) was originally tasked with monitoring agency wide reporting deadlines and was transferred to Executive Director’s Office. SCDEW continues to utilize the master reporting database developed by EPMO that includes relevant identifying information including report name, agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to the Executive Director’s Office on the status of the required filings. The Executive Director’s Office routine reports the status of filings to executive leadership. The Agency’s contact person for the corrective action plan is Jacquelyn Carlen, CFO. The corrective action plan was implemented on June 20, 2021, and is ongoing.

The South Carolina Department of Employment and Workforce (SCDEW) immediately recognized the increased fraud risk presented by the federal pandemic programs. In an effort to deter this obvious fraud threat, SCDEW initially informed every applicant for federal pandemic benefits that they might be required to provide proof of their employment or self-employment at a future time. The USDOL, however, ordered SCDEW to remove this notification because, in the words of one USDOL representative, such a warning might deter a claimant from applying for federal pandemic benefits. USDOL subsequently issued guidance prohibiting states from requiring proof of employment or self-employment as an eligibility requirement to receive federal pandemic benefits. Therefore, all a fraudster had to do to receive federal benefits was simply tell a state they were unemployed as a result of the COVID-19 pandemic. SCDEW was prohibited from requiring that fraudster to prove that they were even employed, let alone that they were unemployed because of the pandemic. Many of the items identified as paid fraudulent claims were caused by SCDEW’s compliance with the USDOL guidelines. SCDEW complied with this guidance, even though it disagreed with USDOL’s highly technical parsing of federal law, and SCDEW advocated for Congress to amend the law to clearly establish commonsense fraud protections. While awaiting Congressional action, SCDEW implemented numerous fraud detection and prevention tools and strategies to minimize the potential fraud exacerbated by lax federal requirements. Unfortunately, Congress did not amend the law until late December 2020. As a result, eligibility determinations made by SCDEW prior to the law change followed the federal guidance for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the federal policies and procedures SCDEW was forced to adopt were not adequate to completely prevent fraudulent claims. SCDEW continues to review, monitor, and enhance eligibility processes and procedures to prevent and detect fraudulent claims. We also updated our internal controls to help mitigate future fraudulent claims. The COVID pandemic created unprecedented challenges for every state workforce agency due to the combination of historic claim volume, the availability of a staggering amount of federal money, and new programs with lax eligibility and verification requirements that had to be implemented quickly, despite often changing federal guidance. These factors created a perfect storm for sophisticated fraudsters to exploit. In response, SCDEW took numerous aggressive steps. In mid-2020, SCDEW required applicants to provide copies of their driver’s license or passport to prove their identity before receiving benefits. SCDEW also implemented identity verification questions through Lexis Nexis that every claimant had to pass before processing a claim. This was further enhanced in March 2021, when South Carolina was one of the first states to implement digital identity verification through ID.me. SCDEW also implemented reCAPTCHA to prevent against bot attacks, implemented new data sharing agreements, and increased the number of staff dedicated to investigating fraudulent claim activity to over fifty at the peak of the pandemic programs. SCDEW continuously reviews its fraud detection and prevention activities to stay ahead of emerging fraud schemes. Since the height of the pandemic, SCDEW has increased its data crossmatching, partnered with the State Law Enforcement Division to have a financial fraud investigator dedicated to unemployment insurance fraud, and made numerous enhancements to its computer systems to combat fraud and preserve the integrity of the unemployment insurance system. Per USDOL data, the agency had the twelfth lowest improper payment rate out of fifty-three programs during the year ending September 30, 2024. For more comprehensive explanation and response, please see August 26, 2024, letter attached from Paul Famolari, Assistant Executive Director of Unemployment Insurance. The Agency’s contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was June 20, 2021, and is ongoing.

Planned Corrective Action: Finance Director will review quarterly report prior to submission. Planned Implementation Date of Corrective Action: Immediately upon notification, June 09, 2025. Person Responsible for Corrective Action: County Administrator and Finance Director

Audit Finding: Finding 2022-002: Submission of Single Audit Management’s Comments on Findings and Recommendation: We concur with the auditor's findings. Management’s Corrective Action Plan: We now are aware of the audit requirements and are committed to compliance. The Organization will engage auditors to perform subsequent period audits, as applicable. Employee / Division Responsible for Execution: Executive Director Timeline and Estimated Completion Date: Effective Immediately

The Tribes, in collaboration with the Interim CFO, will review cash flow projection and monitoring processes to strengthen management of operating and grant funds. The Tribes will obtain external funding, as needed, to meet general fund and reimbursement grant cash needs and to reimburse advance-funded grants for any interfund borrowing incurred. General fund budgets will be evaluated to ensure adequate cash is available for planned expenditures, and procedures will be enhanced to improve the timeliness of billing and collection for reimbursement-based grants. James Russ, Tribal Business Administrator, Wendy Wilson, Interim CFO and Sonia Horne, Grants and Contracts Accountant December 31, 2025

The Tribes will evaluate options to either enter into a collateralization agreement with a financial institution or invest advanced federal grant funds in U.S.-backed securities to ensure compliance with grant requirements. Staff will also receive training on applicable federal regulations governing advanced payments. James Russ, Tribal Business Administrator, Wendy Wilson, Interim CFO and Sonia Horne, Grants and Contracts Accountant December 31, 2025

Audit Finding Reference: 2022-005 Condition: Organizations that expend $750,000 or more in federal awards during their fiscal year are required to have a single audit. Planned Corrective Action: The Organization recognizes the importance of timely compliance with federal single audit requirements. To address this, management has engaged an outsourced CPA firm to provide full-service Controller and CFO support. This firm will monitor federal expenditures throughout the year, ensuring that thresholds triggering audit requirements are promptly identified. In addition, procedures will be established to track all federal awards and deadlines, with periodic compliance reviews performed by the outsourced team. This oversight will ensure that single audits are conducted when required and that federal regulations are met in a timely and accurate manner. Completion Date: December 31, 2024. Name of Contact Person: Jenna Harrity, ED Email: little.folks@aol.com Phone: 617-569-0294

Finding Number: 2022-004 Condition: The Organization was unable to provide supporting documentation to substantiate the allowability and accuracy of the expenses and lost revenue submitted in the portal. Planned Corrective Action: Company is an emergency services (ambulance, first responder, and was instrumental in the administration of the monoclonal antibodies) – healthcare company and was during the pandemic. Company was able to provide general ledger information by personnel classification in aggregate monthly with percentages related to the Covid pandemic. Company changed payroll companies in June 2022 from Trion to DM Payroll – where we were unable to access the payroll registers by personnel name. Medstar has full access to payroll registers through DM Payroll. Contact person responsible for corrective action: Lalainia Budzynowski, VP of Finance Anticipated Completion Date: 06/30/2022 - Completed

Planned Corrective Action: The Quality Management Director and Executive Director have worked together to create a process with appropriate checks and balances regarding moving expense across individual grants and major funds. This process will consist of multiple levels of approval and specific documentation. Any entries will be processed in a timely manner and all expenditure reports will be checked for errors monthly. This process will ensure that expenditure reports are accurate at the time they are submitted for reimbursement. Name of Contact Person: Gwen Taylor, Executive Director

Plan of Action: The District’s plan is a two-pronged approach to ensure that appropriate policies and procedures are in place and that recording of assets whose resources include federal funds will clearly indicate the federal award identification number, who holds the title, the participation rate, the location, use, and condition that the asset is to be put to in accordance with uniform guidance. A. The District will implement a robust Capital Asset Policy to be reviewed and approved by the District’s Board of Directors. Standard Operating Procedures will accompany the policy and will be the standard guidelines in which all capital assets will be treated, regardless of where the funding resources are generated from. B. The District plans to use it’s accounting software, SAGE 50, and capital asset software, FAS, to document funding resources, which should include all the required information as noted in Uniform Guidance. Additionally, capital asset invoices will include proper documentation showing the funding resources and required information. Date of implementation: The policies and procedures will be reviewed by the Board of Directors no later than December 10, 2025, and will be retroactive to July 1, 2025, in order to consistently apply the policy and procedures to FY 2026. The District, if time will allow, may retroactively apply the policy to prior Fiscal Years.

2022‐008 Grant Expenditures (Material Weakness) Recommendation: The Organization’s accounting system should be modified to accommodate expense tracking by individual grant and policies and procedures should be implemented to require direct expenses be assigned to specific grants. A method should be established to allocate indirect costs in accordance with federal regulations. Policies and procedures are also needed to provide appropriate oversight of all grant accounting including reporting. Action Taken (Unaudited): Management has updated its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Dan Watkins is responsible for this corrective action. A review process and coding within the accounting system was completed in January 2025. All invoices and staff time are evaluated for the level of effort towards each grant.

2022‐007 Payroll (Material Weakness) Recommendation: Procedures should be implemented to require appropriate contemporaneous documentation to support time and effort reporting under 2 CFR Part 200. In addition, procedures should also be implemented to require the review and approval of payroll. Action Taken (Unaudited): Management has updated its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Dan Watkins is responsible for this corrective action. The Organization hired a Human Resource Manager June of 2024, moved to ADP for payroll in January 2025 and updated policies and process for review in May 2025. Procedures are in place for review and approval of each payroll.

Due to recent turnovers at UCCAC, program and fiscal staff did not have proper access to the reporting application to timely complete the report. The report was submitted as soon as access to the application was obtained. In addition, UCCAC has given access to multiple staff administrative access to applications. Responsible Person: Executive Director Timeline: 30-60days

Michigan Ability Partners strives to maintain compliance with all HUD requirements, however due to the challenges of social distancing and the requirement of remote work during the COVID era, meeting in person with clients and landlords to obtain signed documents became much more difficult. Staff transitions also contributed to these challenges. The Voucher Manager position—responsible for verifying rent reasonableness and filling open HUD vouchers—was vacated in July 2022 after a brief tenure. Although the role was refilled quickly, the transition resulted in information gaps during lease renewal periods due to the disruption in continuity and knowledge transfer. To help support the growing difficulty of the work, a new position, Housing Administrative Team Lead, was created in November 2022 to have direct responsibility of the Voucher Manager, maintain compliance, and update systems and workflows. More recently, in August 2024, Michigan Ability Partners created an additional position, Sr. Manager of Programs to provide an additional level of review to ensure compliance. To recruit and retain qualified staff, the salaries for these three position have been adequately adjusted. Michigan Ability Partners (MAP) provides outstanding services to the unhoused population of Washtenaw County. Although many staffing disruptions have recently affected some of its operations, MAP is committed to continue to provide exceptional services and maintain a high standard of compliance. Going forward, MAP will continue to work diligently to complete Single Audit Packages in a timely manner

Michigan Ability Partners strives to maintain compliance with all HUD requirements, however due to the challenges of social distancing and the requirement of remote work during the COVID era, meeting in person with clients and landlords to obtain signed documents became much more difficult. Staff transitions also contributed to these challenges. The Voucher Manager position—responsible for verifying rent reasonableness and filling open HUD vouchers—was vacated in July 2022 after a brief tenure. Although the role was refilled quickly, the transition resulted in information gaps during lease renewal periods due to the disruption in continuity and knowledge transfer. To help support the growing difficulty of the work, a new position, Housing Administrative Team Lead, was created in November 2022 to have direct responsibility of the Voucher Manager, maintain compliance, and update systems and workflows. More recently, in August 2024, Michigan Ability Partners created an additional position, Sr. Manager of Programs to provide an additional level of review to ensure compliance. To recruit and retain qualified staff, the salaries for these three position have been adequately adjusted.

2022 – 005: Reporting (Compliance; Internal Controls Over Compliance) Material Weakness – 93.U01 Title V Condition: The Organization was unable to provide any of the required reports for the Title V program, including the financial report, activity narrative, third-party income report, GPRA/GPRAMA, urban data standards, and property inventory. Without these reports, we were unable to perform the necessary audit procedures to assess compliance with federal requirements. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software used and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly so this should take care of this issue. Management has worked on procedures and training to assure financial report, activity narrative, third-party income report, GPRA/GPRAMA, urban data standards, and property inventory are completed.

2022 – 003: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Compliance; Internal Controls Over Compliance Material Weakness – 93.U01 Title V Condition: The Organization’s general ledger did not allow for sufficient identification of transactions related to the major program, Title V. Title V expenditures were recorded through journal entries without supporting transaction-level detail. Because of this, the population of expenditures could not be tied to individual transactions, and pulling samples from this population would not provide a reasonable basis for drawing conclusions about the population tested. As a result, we were unable to select transactions for testing or perform the necessary audit procedures to assess compliance with federal requirements. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software used, and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly.

WHRSD has recently redesigned its Chart of Accounts and deployed a current ERP software program to assist in controls of expenditures of all accounts including grants. WHRSD will be completing a comprehensive review of all Business Office Procedures in the fall of 2025, and plans to update/implement updated standard operating procedures to ensure compliance with Local, State, and Federal laws.