Corrective Action Plans

2022-003 – ELIGIBILITY Material Weakness/noncompliance Auditee’s Response and Planned Corrective Action The Windsor Housing Authority currently contracts with J.D. A’melia for all Housing Choice Voucher Program services. HCV staff have a broad range of duties covering activities from application, waitlist management, initial briefing for new participants, resident processing through termination of assistance. They will also perform all property activities related to compliance with WHA’s lease for all our properties and they will have extensive contact with landlords and tenants participating in the HCV programs. More specifically, HCV staff responsibilities include but are not limited to:  Lease-ups including new tenant orientation Monthly close-out  Waitlist Management Administrative & clerical functions  Inspection coordination Processing applications  Annual and interim recertification HUD reporting  Landlord services Determining eligibility  Direct deposit set-up EIV  Calculations & payment authorization to landlords & tenants admin fees calculation and payment Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

Finding 2022-006 Federal Agency Name: U.S. Department of Agriculture Assistance Listing Number: #10.766 Program Name: Community Facilities Loans and Grants Cluster, Community Facilities Loans and Grants Compliance Requirement: Other Finding Summary: The Authority does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards being audited. We were requested to draft the schedule of expenditures of federal awards. Responsible Individuals: Doran Hammett, Chief Financial Officer Corrective Action Plan: Ongoing

Misapplication of the Sliding Fee Scale The department responsible for gathering and recording patient income data, and applying sliding fee discounts, experienced high attrition rates due to the role being entry-level. Recognizing these challenges, the Organization is in the process of revising the training plan for this department and establishing a quality assurance process for monitoring. Additionally, the Organization will review and revise the sliding fee policy to enhance clarity of the process for application of discounts and proof of income documentation. Responsible Parties: Mark Groeller, Compliance Director, Lisa DeMallie, Associate Vice President of Patient Experience, and Melissa Darko, Revenue Cycle Director Estimated Completion Date: December 31, 2024

FINDING 2022-005 Finding Subject: CDBG ‐ Entitlement Grants Cluster ‐ Period of Performance Summary of Finding: The county did not have properly designed internal controls in order to prevent or detect errors in the general ledger for activities related to adjustments to Community Development Block Grant funds during the transition and implementation of the Oracle accounting system. Contact Person Responsible for Corrective Action: Dan Ciecierski, Comptroller Contact Phone Number and Email Address: 219-755-3137 | ciecidx@lakecountyin.org Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Lake County has begun execution of a comprehensive strategy in order to address the lack of internal controls around its financial transactions and reporting in a number of ways. The following will address control issues identified in these areas: - Financial Transactions and Reporting - Employee Benefit Accrual (EBA) Fund - Cash and Investments - Receipts - Journal Entries - Financial Statement & Reporting First, a more qualified consulting firm has been hired to assist on two important fronts related to the new accounting system: 1. The first is the reimplementation of the Oracle accounting software which is inclusive of correcting data and poor configurations from the prior consultant, and deploying additional appropriate functionality to allow the County to optimize Oracle to suit the accounting needs from a process standpoint as well as an internal control perspective. Oracle in and of itself allows the county to implement strategic preventative internal controls via role-based access features. Said differently, Oracle has a more robust and granular ability to automatically create separation of INDIANA STATE BOARD OF ACCOUNTS 41 duties among employees and departments simply by restricting the ability to perform actions which should be naturally segregated to mitigate risk of error. 2. Secondly, the managed services portion of the consulting contract will aid the County in running the business activities related to both the Oracle Human Capital Management (HCM) module and the Enterprise Resource Planning (ERP) module (Purchasing, Accounts Receivable, Accounts Payable, and General Accounting). Another initiative being executed to address the lack of internal controls is to attract, and hire qualified professionals who have years of real world, practical experience in the field for which a job relates to. During the original implementation of the Oracle system there was no one who fully understood, nor had a background in the professional field of accounting in the Auditor’s Office. The County has hired a Comptroller who passed the CPA, and has spent their entire career in the field of accounting. This individual has worked in the corporate utility and banking industries and has experience in GAAP reporting, regulatory reporting, internal controls, and overall general accounting. Additionally, the Comptroller has been involved with internal and external audit compliance as well as the installation, user acceptance testing, and transition of new accounting software. In order to mitigate the risk of error for any adjusting entries made which are recommended by consultants, the Comptroller of Finance must review and approve these entries. Anticipated Completion Date: 1. This process has already been put into place and is being executed.

FINDING 2022-004 Finding Subject: CDBG – Entitlement Grants Cluster—Reporting Summary of Finding: Condition and Context: The County did not have internal control procedures over the Quarterly Reports (PR29), IDIS Section 3 Performance Report, and NSP Quarterly Reports. One individual prepared or generated the report without a review or oversight process. Additionally, the County’s internal controls were not consistently documented over the draw down requests for the CDBG grant during the audit period. The draw down requests were entered into IDIS, which then becomes the basis for several of the reports. The control presented by the County was that one individual prepared and entered the request, which would then be printed, and another individual would review and sign the printed request to document the review. Of the thirteen reimbursement requests tested, control documentation for eight of the requests were printed and signed during current period, after the documentation was requested. The creation of documentation of the control procedure did not support that internal controls were effective during the audit period. Recommendation: We recommended that the County's management design and implement a proper system of internal controls, and retain documentation of its system of internal controls, to ensure compliance with reporting requirements. Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 and brownta@lakecountyin.org Views of Responsible Officials: LCCEDD concurs with the audit finding. Concurrence: The Fiscal Officer from the Audit Period was new to the position and her training was focused on the changes to the financial systems at the county over the DRGR quarterly reporting of NSP actions. Further, Finding 2022-003 also caused some of the reporting issues with CDBG of having two CDBG funds and posting errors to these funds. The current LCCEDD Fiscal Officer found the problems during the audit and corrective actions were done retroactively to address this part of the finding with the drawdown requests. The CDBG drawdowns were submitted into IDIS by the Fiscal Officer who printed out the drawdown request. These printouts were then given to the Executive Director or the Deputy Director who then went into IDIS and approved the drawdown request, then print out the IDIS drawdown approval and return the request and the signed approval back to the Fiscal Officer. LAKE COUNTY COMMUNITY ECONOMIC DEVELOPMENT DEPARTMENT 2293 N. Main Street - Crown Point, In 46307 Tel. (219) 755-3225 www.lakecountyin.org INDIANA STATE BOARD OF ACCOUNTS 38 Description of Corrective Action Plan: LCCEDD staff have already adopted changes in internal controls to correct the CDBG reporting deficiencies as described in Finding 2022-003. Further, management will oversee compliance with current policies and the new quarterly reconciliations. LCCEDD policies will be updated to make the following changes: General Management and Oversight: On an on-going basis, the Director will meet with Department staff to determine if training or technical assistance is needed to complete HUD reporting requirements in a timely and accurate manner. NSP Quarterly Reports: To be followed until the HUD field office indicates QPR reports are no longer needed due to grant closeout: 1. Before the close of each month, the Fiscal Officer will create receipts and draws as needed in HUD’s DRGR system to reflect funds receipted or expended by the County. 2. At the close of each quarter, the Fiscal Officer will prepare and submit the quarterly report in DRGR for the NSP1 and NSP3 grant allocation. To prepare the report, the Fiscal Officer will reconcile all expenses and receipts posted in the County’s general ledger system for the NSP programs with the receipts and drawdown requests recorded in in HUD’s DRGR reporting system. 3. Before submitting the NSP QPR Report in the DRGR system, the Deputy Director will review and approve the prepared reconciliation and QPR Report. Any discrepancies between the two systems will be reported to the Auditor and the Department Director to determine corrective actions. 4. Within 30 days of the close of each calendar quarter, the Fiscal Officer will submit the NSP QPR Report via DRGR. The Fiscal Officer will maintain a copy of the NSP QPR and the corresponding reconciliation in their program files. Cash on Hand Reports: 1. At the close of each quarter, the Fiscal Officer will prepare and submit the Cash on Hand Report within thirty days of the close of the quarter. The Fiscal Officer will reconcile all expenses and receipts posted in the County’s general ledger system with the receipts (report PR09) and drawdown requests (report PR07) in HUD’s IDIS Online reporting system. 2. Before submitting the Cash on Hand Report in the IDIS Online system, the Deputy Director will review and approve the prepared reconciliation and Cash on Hand Report. Any discrepancies between the two systems will be reported to the Auditor and the Department Director to determine corrective actions. 3. Within 30 days of the close of each calendar quarter, the Fiscal Officer will submit the Cash on Hand Report via IDIS Online. The Fiscal Officer will maintain a copy of the Cash on Hand report and the corresponding reconciliation in their program files. INDIANA STATE BOARD OF ACCOUNTS 39 Section 3 Reporting: 1. As part of the application review, the Deputy Director will determine the applicability of the Section 3 requirements for each proposed project. 2. For projects where Section 3 is applicable, the Deputy Director will ensure that staff administering the project are familiar with the Section 3 requirements and understand the forms and reporting required to properly report Section 3, including the determination of total labor hours worked, labors hours worked by Section 3 and Targeted Section 3 workers, and corresponding certifications. 3. The County will collect Section 3 reports from subrecipients administering projects throughout the period of performance. If the project meets Section 3 benchmarks, the County will consider the activity to be in full compliance with Section 3. If the project does not meet one of the Section 3 benchmarks, the County will require reporting on the qualitative efforts that the subrecipient made to try to reach the benchmarks. 4. Section 3 information collected for each project will be reported in IDIS Online. The Section 3 information must be reported annually before the submission of the annual report (CAPER) to HUD. Anticipated Completion Date: Part of the corrections have already been put into place and the Policy and Procedure Manual will be amended in April of 2025 after the Lake County Redevelopment Commission adopts appropriate changes.

FINDING 2022-003 Finding Subject: CDBG – Entitlement Grants Cluster—Program Income Summary of Finding: Condition and Context: The County received program income through various loan programs it offered to qualifying individuals. Once the County received a loan payment, the receipt was posted into the financial accounting system of the County and recorded in a grant fund. The amount received was also to be recorded in the Department of Housing and Urban Development’s (HUD) Integrated Disbursement & Information System (IDIS) website. The recorded program income in IDIS would then appear on the Drawdown Report by Voucher Number report (PR07). No internal control process had been established over the program income compliance requirement. One individual was responsible for notifying the Auditor's office when program income money was received, in order for it to be receipted in the County’s financial accounting system. The same individual was also responsible for reporting the same on IDIS site. No controls were established to ensure the program income that was recorded in the financial accounting system was also reported on IDIS site and the PR07 report. Additionally, four receipts totaling $38,960 were selected for testing from the County’s receipt ledger. These four receipts were unable to be located on the PR07 report provided for audit. One of the four receipts was recorded in the IDIS system after information regarding the receipt was requested. The receipt was not in the PR07 report that had been provided for audit when we were provided information documenting it being recorded in IDIS. Furthermore, we were unable to verify the total amount recorded in receipt ledger to the total reported on PR07 report. The County’s ledger was greater than the PR07 report by $30,324 and is primarily attributed to under reporting of program income in IDIS as identified above. Recommendation: We recommended that the management of the County establish a system of internal controls to ensure that all program income received is properly reported in the IDIS system and expended prior to drawing down federal awards. Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 and brownta@lakecountyin.org Views of Responsible Officials: LCCEDD concurs with the audit finding. LAKE COUNTY COMMUNITY ECONOMIC DEVELOPMENT DEPARTMENT 2293 N. Main Street - Crown Point, In 46307 Tel. (219) 755-3225 www.lakecountyin.org INDIANA STATE BOARD OF ACCOUNTS 36 Description of Corrective Action Plan: LCCEDD staff have already adopted changes in internal controls to correct the Program Income reporting deficiencies. The process is as follows: 1. All incoming checks into the department are first reviewed by the Deputy Director. The Deputy Director determines the source of income (i.e. CDBG, HOME, NSP) and the correct receipt type (program income, repayment, homebuyer). The Deputy Director records the IDIS number of the project on the check before giving it to the Fiscal Officer. 2. The Fiscal Officer records the receipt on an internal schedule of receipts and submits the check to the County Auditor with the check deposit form with the IDIS number and correct fund and account number for deposit. 3. Once the County Auditor posts the receipt to the County’s general ledger, the Fiscal Officer records the Auditor’s receipt into HUD’s IDIS Online reporting system. 4. At the close of each quarter, the Fiscal Officer will prepare and submit the Cash on Hand Report within thirty days of the close of the quarter. The Fiscal Officer will reconcile all expenses and receipts posted in the County’s general ledger system with the receipts (report PR09) and drawdown requests (report PR07) in HUD’s IDIS Online reporting system. Before submitting the Cash on Hand Report in the IDIS Online system, the Deputy Director will review and approve the prepared reconciliation and Cash on Hand Report. Any discrepancies between the two systems will be reported to the Auditor and the Department Director to determine corrective actions. 5. Within 30 days of the close of each calendar quarter, the Fiscal Officer will submit the Cash on Hand Report via IDIS Online. The Fiscal Officer will maintain a copy of the Cash on Hand report and the corresponding reconciliation in their program files. 6. On an on-going basis, the Director will meet with Department staff to determine if training or technical assistance is needed to complete HUD reporting requirements in a timely and accurate manner. Anticipated Completion Date: A policy and procedure amendment will be written by the end of this year and presented to the Lake County Redevelopment Commission for their March 2025 meeting for adoption.

Federal Award Finding and Questioned Costs Finding Reference: 2022-004 – Other finding – SEFA Preparation Federal Program Information Federal Agencies: United States Department of Homeland Security Awards: Assistance Listing Number 97.036 – COVID-19 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) Award Periods: January 20, 2020 – May 11, 2023 Description: Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Recommendation The System should update its policies and procedures and internal controls, specifically the process to accumulate and report FEMA expenditures of federal awards to be in accordance with the FEMA Schedule requirements outlined above. View of responsible officials The System agrees with the comment and has developed a plan to correct the finding. Corrective Action Planned The System has trained all applicable staff on the appropriate interpretation of FEMA Public Assistance Grant Program guidance for reporting Assistance Listing 97.036 expenditures in the SEFA. Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Planned completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2024

2022-003 – Reporting Corrective action planned: The District will save the emails that show they sent the audit to the USDA in the audit folder. Anticipated completion date: Immediately Contact person responsible for corrective action: Controller

2022-002 – Special Tests and Provisions Corrective action planned: The District will open a new bank account that will hold the debt reserve amount. A deposit into the debt reserve account will be made monthly via auto transfer on the tenth of each month until December 2027. There will be one withdrawal from this account done annually to transfer funds to a CD. The annual payment amount will have its own account with the amount of the next years’ payment. Anticipated completion date: November 30, 2024 Contact person responsible for corrective action: Controller

The School District will review the Uniform Guidance requirements and ensure all expenditures are accurately reported on the School District’s federal schedule.

As of October 2022, EPEC updated our grant expense approval process. As with all purchases and payroll, grant expenditures will be approved by a Director (Director team consists of: Executive Director, Director of Finance, Director of Outreach, and Director of Shelter), and when paid, will be assessed for accuracy again by EPEC’s contracted CPA. Approvals will be documented on each paper bill or electronically via email or DocuSign, when appropriate.

Recommendation: The Association continue to work internally and with software vendors and outside consultants as needed to implement a chart of accounts and custom reporting tools that will assist them in complying with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Containment Upon discovering flaws in the new financial system we immediately hired a third-party consultant who was experienced with our newly implemented software system (MIP) as well as fiscal best practices. This consultant was made available to the Fiscal team at the time, offering support in the transition to the new software. Root Cause Not all information was migrated into the new software system in a timely manner, making it difficult to use at its full potential. OCCDA had a large turnover in the fiscal team during the audit processing, making it difficult to find information or pull reports that were not fully migrated. The transition to the new fiscal software was during the height of the COVID-19 pandemic, making it difficult to complete training and migration of the new system. Action Taken Immediately, the OCCDA Executive Director worked directly with the remaining team members to ensure business continuity in the fiscal department. Promptly, the chart of accounts was updated to track grants separately as well as any carry-over funds. Also, an additional support membership was purchased through NP Solutions which specializes in MIP implementation and software. During the recruitment and hiring of staff, the new Fiscal/HR Director has delegated tasks that streamline duties, creating separation of duties where appropriate to ensure effective internal controls. The fiscal team positions have not only been delegated separate tasks but have also been provided in-depth training on them. The leadership team has been trained on allowable costs and charged with reviewing their assigned budgets each month. Already our Fiscal Manager has implemented running monthly spending reports. The Leadership team members work monthly with the Fiscal Manager to review the reports and line-by-line reports when appropriate to seek clarification and ensure that we are reporting accurately. The Fiscal/HR Director, Fiscal Manager, and Fiscal Assistant were sent to an in-depth MIP training this year to increase skills and knowledge of software to align with GAPP practices. Also, the Fiscal/HR Director has completed a Uniform Guidance training this year and our Fiscal Manager will be taking this training in the coming year. Moving forward in 2024, the Fiscal Manager will continue to update the chart of accounts to organize the general ledger and enhance our reports for ease of use and ensure accuracy. On or before March 2024 the chart of accounts will be updated. For example, each time a new funding source is received a new program code will be created allowing for tracking and reporting. Our internal policy indicates that we will have regular reviews and ensure compliance. Our new Fiscal Manager has current relationships with the software team allowing for questions to be asked and answered quickly. We are continuing to work with software consultants closely in updating the usability of our software and correcting our mapping of GL accounts. We have reorganized the chart of accounts in support of the software consultants, we have added additional program numbers to track grants separately by funding year to allow us to close each grant yearly. This will allow us to process reports by funding source by year/grant. Name(s) of contact person(s) responsible for corrective action: Fiscal Manager Planned completion date for corrective action plan: In process to be completed by March 2024 (Q1)

Finding 2022-017 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-0001 COVID-19 Emergency Solutions Grant Program - 14.231, Award number E-20-MW-20-0001 Management’s Response: Management agrees it is important to adhere to the terms of the award. During 2022 we experienced a cyber event that delayed timely payments for certain supplier invoices. Details on the dates of late payments are requested to determine if the issue was a system wide shut down due to the cyber event April – June 2022. Regardless, the new Workday system is now fully implemented (as of January 2024) and we will work to use the system to ensure timely payments. Views of Responsible Officials and Corrective Action: Departmental stakeholders should work with central accounting to be sure payments are made in time and develop solutions where there could potentially be a shortfall. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Finding 2022-016 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Management’s Response: Management agrees it is critical to ensure spending occurs within the applicable expenditure periods. In the new financial management system (Workday), we have established parameters to fence the applicable expenditure periods. Further we are making gains to close out awards to further disallow spend outside the applicable expenditure periods. There was departmental turnover within the department at the end of 2022 with a loss of knowledge transfer during the change in personnel. Views of Responsible Officials and Corrective Action: With the aid of technology available through our new ERP system, management plans to enhance operations by having training documents and processes for various awards so as personnel attrition occurs there is continuity in processes. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Finding 2022-015 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Management’s Response: Management agrees that the matching component should be tracked to ensure compliance with the terms of the award. Views of Responsible Officials and Corrective Action: With our new ERP system, in the grant/award module, the Unified Government of Wyandotte County & Kansas City KS are working with departments to establish match components and trackable spend items to enhance compliance with award terms. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Finding 2022-013 U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083, Award Number EMW-2019-FF-0819 Management’s Response: Management agrees spend controls are an important part of grant compliance. Management continues to improve compliance and controls over awards to ensure compliance. In 2023 we converted to a new ERP system and part of the conversion was implementing spend controls to aid in compliance for awards to minimize future issues. Views of Responsible Officials and Corrective Action: Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

2022-002 Special Education Cluster - Assistance Listing Numbers 84.027, 84.173 Recommendation: We recommend procedures to maintain records sufficient to detail the history of all procurements be strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As of 7/1/2022, Framingham Public Schools will no longer claim the Massachusetts Chapter 30B SPED exemption (Appendix A. #8 & #22) for any SPED contracts being paid with federal funds. Instead, these contracts will be subject to the standard Chapter 30B procurement policies. FPS Executive Director of Finance and Operations, Lincoln Lynch IV, will meet with Director of SPED, Laura Spear, and City of Framingham Chief Procurement Officer, Jennifer Pratt, to make them aware of this finding and request that 1) all SPED grant funded contracts going forward will follow standard Chapter 30-B procurement policies and 2) City of Framingham updates their accounting procedures/procurement policies to reflect this change by 7/1/2022. Name(s) of the contact person(s) responsible for corrective action: Lincoln Lynch, IV - Executive Director of Finance and Operations Framingham Public Schools Planned completion date for corrective action plan: In progress

Corrective Action Plan Finding 2022-004 Improve Time and Effort Documentation Planned Corrective Action: The Housing and Economic Development Department will establish a process to document time and effort certifications for salaried employees, and ensure that compliance is monitored on an ongoing basis by the HCD Division Director. Anticipated Completion Date: May 1, 2023 Contact Person: Mary Davis, Interim Department Director, Housing and Economic Development and Division Director, Housing and Community Development

Audit Finding Reference: 2022-003 Improve Controls and Documentation over Payroll Process Planned Corrective Action: The Portland Public School District's payroll operations have been under strain since its conversion to a new software system (Munis) in January 2019. Certain modules and functionalities were not set up completely or correctly prior to launch, which necessitated workarounds, time-consuming manual processing, and error correction. These challenges were compounded by staff turnover, staffing shortages, and the heightened pressures across the district caused by the pandemic. As a result certain systems, processes, procedures, and documentation protocols have weakened over this time. PPS is aware of this and has been working toward a permanent solution to the root cause of the payroll challenges. In collaboration with outside consultants, PPS has entered into an agreement to transition to ADP as a third-party payroll provider for the district, with expected implementation in fall 2023. PPS has retained a project manager for the transition, whose focus will not only be the technical software transition but also ensuring that sound policies, procedures, and controls are in place alongside system capabilities that meet the needs of the district. Additionally, PPS intends to invest in additional HR staff in order to implement new workflow that ensures appropriate segregation of duties, review, and documentation of employee pay information. Name of Contact Person: Terry Young Ed.D Executive Director of Operations Portland Public Schools 353 Cumberland Avenue Portland, ME 04101 Direct: (207) 842-5333 Anticipated Completion Date: 11/1/2023

Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Southwestern Christian University will designate multiple staff to oversee the guidelines and disbursements of all federal money. The Interim CFO is responsible for the reconciliation of expenditures and drawdowns from any future federal funds. Person Responsible for Corrective Action Plan: Bill Martin, Interim CFO Anticipated Date of Completion: Immediately

Department of the Treasury, Passed through North Dakota State Water Commission Federal Financial Assistance Listing 21.027 COVID-19 - Coronavirus State and Local Discal Recovery Funds Other Material Weakness in Internal Control Over Compliance Finding Summary: The District does not have an internal control system designed to provide for a complete and accurate Schedule of Expenditures of Federal Awards, as required by Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Responsible Individuals: General Manager (Vacant) and Jan Lee, Office Manager Corrective Action Plan: The District will implement procedures necessary to complete an accurate Schedule of Expenditures of Federal Awards. Anticipated Completion: December 31, 2024

Finding 2022-003: Reconciliation of Accounts Federal Program: Research and Development Cluster (Education and Human Resources)Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022) Condition: The year-end schedules for federal grants receivable, net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 10/15/2024 Responsible Official: Michael Brosnan, CFO

Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023)Condition: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances. Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments. The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated during March, 2024 The staff will be trained on generating journal entries previously prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024 The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received. Anticipated Completion Date: January 2025 Responsible Official: Michael Brosnan, CFO

Finding 2022-007 Federal Agency Names: Department of Health and Human Services and Department of Agriculture Program Names: COVID-19 Provider Relief Fund and American Rescue Plan and Community Facilities Loans and Grants Federal Financial Assistance Listings: #93.498 and #10.766 Initial Fiscal Year Finding Occurred: 2022 Finding Summary: The Corporation does not have the internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards (Schedule) being audited. The Corporation requested Eide Bailly LLP to draft the Schedule. Responsible Individuals: Renee Henry, Corporate Controller Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the Schedule. We will continue to have our auditors prepare the Schedule as part of their single audit. Anticipated Completion Date: Ongoing

Finding 2022-006 Federal Agency Names: Department of Health and Human Services and Department of Agriculture Program Names: COVID-19 Provider Relief Fund and American Rescue Plan and Community Facilities Loans and Grants Federal Financial Assistance Listings: #93.498 and #10.766 Initial Fiscal Year Finding Occurred: 2022 Finding Summary: The Corporation does not have the internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards (Schedule) being audited. The Corporation requested Eide Bailly LLP to draft the Schedule. Responsible Individuals: Renee Henry, Corporate Controller Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for the preparation of the Schedule. We will continue to have our auditors prepare the Schedule as part of their single audit. Anticipated Completion Date: Ongoing