Corrective Action Plans

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. CMHA is aware that the HAB/MRI software does not store waitlist reports by date processed and since then, CMHA has been saving Excel files of the waitlist reports. The applicants that were selected for the audit were applicants that had preference points. All applicants with preference points were contacted at the same time to be informed that they were eligible for a voucher. The CMHA waitlists were ran by preference points and time/date of application. Once those applicants were pulled the waitlist was not saved to Excel. The preference point list was then sorted alphabetically for sign in purposes and tracking of applicant documentation. This is the list that was provided to the auditor. Melissa Beadle, Deputy Director, will be responsible to implement this corrective action by June 30, 2025.

2024 –1 Segregation of Duties Name of contact person: Kim Wells, Finance Officer Corrective Action: The duties are separated as much as possible with limited staff and alternative controls are in place to provide reasonable assurance that the financial statements are not misstated. At this time, it would be cost prohibitive to add personnel just for segregation of duties. The Town recognizes that reasonable assurance takes into consideration that the cost of internal control should not exceed the benefits. The manager or designated alternate is control for most of the finance functions such as review of accounts payable and bank statements. The Mayor or Commissioner manually signs checks, so there is a second review before the checks are mailed. The Clerk mails the payable checks. The clerk prepares the deposits and deposits with bank and the Finance Officer records. Purchase card transactions for public works is entered by senior administrative assistant. The Board receives check register, cash balances and revenue and expenditure review on a monthly basis. The Town continues to review possible segregation of duties, if personnel expertise allows. Proposed Completion Date: The Town has implemented the segregation of duties as much as possible without hiring additional personnel that is cost prohibitive at the moment. We have implemented review procedures with management that we believe would prevent any material misstatements of the financial statements. Since the manager is the designated control for finance functions, there is an alternate designated by the Manager.

Our Organization has developed a Monitoring Policy to have better oversight of our sub-recipients. Our Chief Executive Office will implement this Monitoring Policy. The Grant Coordinator, will oversee the direct communications related to sub-recipients monitoring. The implementation of enhanced monitoring tools and documentation standards will be completed by June 30, 2025

Federal Award Finding Finding 2024-001 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: Federal Financial Assistance Listing 14.195 Program Name: Section 8 Project-Based Cluster – Project Based Rental Assistance (PBRA) – Section 8 Housing Assistance Payment Program Finding Summary: Material Weakness in internal control over compliance was found in relation to owner’s performance of housing quality inspections. Annual housing quality inspections did not occur at one of the properties operating under Section 8 during 2024. The cause was turnover at the property management level and incomplete monitoring controls. Corrective Action Plan: The Housing Company will enhance its inspection process to ensure annual inspections are completed and reported for all properties. The plan includes the following steps: 1. Regional Managers will collect inspection data and enter it into a centralized tracking system. 2. The Operations Manager and/or Director of The Housing Company will review the tracker semi-annually to verify completeness. 3. Any incomplete inspections will be promptly identified and addressed to maintain annual inspection compliance. 4. The centralized tracker will be stored in an easily accessible location for authorized personnel. 5. Follow-up actions will be taken to complete any outstanding inspections in a timely manner. Responsible Individual: Erin Anderson, Director Anticipated Completion Date: Immediately – March 27, 2025. Very truly yours, Erin Anderson Director The Housing Company

Finding No. 2024-003 Department(s): New York City Administration for Children’s Services and Department of Education Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: The City is planning to transition to the New York State IT system once it is fully developed and implemented by the New York State Office of Children and Family Services and New York State Information Technology for the Child Care Assistance Program. The State IT system will be programmed to reflect current State policy on authorized hours, mitigating the risk of this error in the future. In the interim, The City will implement a short-term, manual solution that will ensure enrollments match authorized hours with regard to full time or part time enrollment and days of enrollment. The first step of the manual solution requires a feasibility analysis to see if it is possible to add a field for recording authorized hours into The City's IT system of record. DOE: The DOE will continue working with ACS to ensure compliance with internal controls, applicable state and federal statutes, regulations, requirements and guidelines. The internal controls include a quality assurance check process on submitted eligibility applications. Anticipated Completion Date: ACS: August 2025 and ongoing DOE: Ongoing Person(s) Responsible for Implementation: ACS: Shari Gruber, Associate Commissioner, Policy and Compliance, Division of Child & Family Well-Being, shari.gruber@acs.nyc.gov, (212) 393-5109 DOE: Meg Barboza, Senior Director of Program Enrollment, mbarboza@schools.nyc.gov, (212) 287-1996 Jodina Clanton, Eligibility and Senior Director of Policy, jclanton@schools.nyc.gov, (212) 287-1927

Finding No. 2024-004 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In November of 2023, HRA hired an Executive Director for the Home TBRA program, updated the quality assurance evaluation tool and trained staff on the differences of budgeting the “gross” and “net” income. Note that HRA began closing out the TBRA tenants with renewal lease dates starting on 8/1/2023, as the program fully closed and transitioned to the City Fighting Homelessness and Eviction Prevention Supplement (“CityFHEPS”) by the 6/30/24 HRA- Housing Preservation and Development Memorandum of Understanding expiration date. Although the rental assistance portion of the HOME TBRA program began phasing out, the following corrective actions were implemented as part of the Fiscal 2023 Single Audit recommendation: • Supervisory staff were retrained on case review and instructed to do a thorough and comprehensive review of the budget and documentation received to inform case decisions. There have been on-going team and individual meetings, informational sessions and trainings with staff involved with TBRA to improve performance and outcome. Anticipated Completion Date: Not Applicable. As noted above, the Rental Assistance portion of the program has been taken over by CityFHEPS. Person(s) Responsible for Implementation: Jordan Worrell, HTBRA Executive Director worrellj@hra.nyc.gov (929)-252- 5403

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County has policies and procedures as well as systematic processes and oversight set up to ensure accurate assessments and determinations are made regarding the Federal or Non-Federal Eligibility of youth in the Foster Care system. It is Solano County’s policy to conduct these assessments at the onset of the case and ensure quality documentation. In addition, the Foster Care unit has a Lead worker and Supervisor who conduct periodic reviews of open cases to ensure accuracy of documentation and adherence to timelines are met. The specific corrective actions identified in this audit found errors related to the migration of data to the CalSAWS program in 2023, where an identified payment was incorrectly identified (Non-Federal to Federal) due to errors or information which existed in CalWin and were transferred improperly to CalSAWS. These conversion errors occurred automatically. As a result, the Foster Care Eligibility Unit has implemented the following changes. • Correction to identified payment: o The identified case was corrected immediately, and all payments adjusted as appropriate. • Changes to workflow to ensure accuracy: o The entire caseload of open Foster Care Eligibility cases will be reviewed to ensure that the original determination or as found in the FC3 or FC3A and granting comments, is correctly input in CalSAWS, and any payment errors corrected as needed. o The case aid code (noting eligibility type) will be included next to the youth’s name to ensure that it shows in the workload report in CalSAWS to ensure the information is easily accessible and any future errors can be identified. o Cases will be reviewed to ensure the above changes are completed through the unit supervisor’s ongoing qualitative review of cases. • The Foster Care Eligibility Supervisor will discuss the findings and requirement with subordinate staff in the following ways: o Unit meeting communication regarding Corrective Action findings and Agency steps to remediate. o Issue a reminder to all staff regarding the above remediation plan. Responsible Individual(s): Kim McDowell, Social Services Manager Neely McElroy, Deputy Director, Child Welfare Services Anticipated Completion Date: May 31, 2025

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/24 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County has policies and procedures as well as systematic processes and oversight set up to ensure accurate assessments and determinations are made regarding the Federal or Non-Federal Eligibility of youth in the Foster Care system. It is Solano County’s policy to conduct these assessments at the onset of the case and ensure quality documentation. In addition, the Foster Care unit has a Lead worker and Supervisor who conduct periodic reviews of open cases to ensure accuracy of documentation and adherence to timelines are met. The specific corrective actions identified in this audit found errors related to the migration of data to the CalSAWS program in 2023, where two cases were inadvertently converted from Non-Federal to Federal cases due to errors or information which existed in CalWin and were transferred improperly to CalSAWS. These conversion errors occurred automatically. As a result, the Foster Care Eligibility Unit has implemented the following changes. • Corrections to identified cases: o The two identified cases were corrected immediately, and all payments adjusted as appropriate. • Changes to workflow to ensure accuracy: o The entire caseload of open Foster Care Eligibility cases will be reviewed to ensure that the original determination or as found in the FC3 or FC3A and granting comments, is correctly input in CalSAWS, and any payment errors corrected as needed. o The case aid code (noting eligibility type) will be included next to the youth’s name to ensure that it shows in the workload report in CalSAWS to ensure the information is easily accessible and any future errors can be identified. o Cases will be reviewed to ensure the above changes are completed through the unit supervisor’s ongoing qualitative review of cases. • The Foster Care Eligibility Supervisor will discuss the findings and requirement with subordinate staff in the following ways: o Unit meeting communication regarding Corrective Action findings and Agency steps to remediate. o Issue a reminder to all staff regarding the above remediation plan. Responsible Individual(s): Kim McDowell, Social Services Manager Neely McElroy, Deputy Director, Child Welfare Services Anticipated Completion Date: May 31, 2025

Federal Agency: U.S. Department of Agriculture Program/Cluster: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number: 10.557 Pass‐through: California Department of Public Health Award No. and Year: 22-10294 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: Condition #1. Five (5) instances out of 60 cases were missing all eligibility documentation. This included the documentation of the determination of eligibility and redetermination in the period under audit. The missing documentation included the records to evidence compliance with the eligibility criteria. Condition #2. Two (2) instances out of 60 cases were missing the Self Declaration Statement form when the applicant was unable to provide acceptable documentation for proof of income, proof of address, or proof of identification. Response to Condition #1 Per California Department of Public Health, Women, Infant, Children division (CDPH/WIC), the categories of non-breastfeeding, breastfeeding, and partially breastfeeding women files remain accessible to the local agency. For children five years of age, the files are purged six months after the fifth birthday. The WIC WISE records for the 5 files were not available due to the file purge by CDPH/WIC, therefore the auditor was unable to determine compliance to eligibility requirements for each of the five files. The auditor suggests the local agency retain eligibility documents. According to the California WIC Policy and Procedure Manual, WIC WISE Forms JOB AID section, eligibility documents provided by an applicant or a re-certifying client are not required to be retained by the local agency. The County has communicated this finding to CDPH/WIC and the risk it presents. At this time, the County is working with CDPH/WIC to address this finding. Specific Corrective Plan Procedures addressing Condition #1 Staff participate in a robust Quality Assurance (QA) plan which involves periodic file reviews and observations as documented in Solano County’s Continuous Quality Improvement (CQI) Monitoring Plan. Additionally, CDPH/WIC conducts a Program Monitoring Visit (PMV) every two years which includes a random record review of the agency’s compliance to eligibility policies. Solano County WIC program will continue to conduct the QA plan, and participate with the CDPH/WIC PMVs. Response to Condition #2 Solano County agrees with the finding. This use of the Self Declaration Statement (SDS) is a specific consideration in the QA plan. The WIC Supervisor was aware of the matter as it was discovered that both SDSs were missing from the family file as part of a regular QA review. The error was addressed with the employee shortly after the mistake occurred. Specific Corrective Plan Procedures addressing Condition #2 Staff participate in a Quality Assurance (QA) plan which involves periodic file reviews and observations as documented in Solano County’s Continuous Quality Improvement (CQI) Monitoring Plan. Additionally, CDPH/WIC conducts a Program Monitoring Visit (PMV) every two years which includes a random record review of the agency’s compliance to eligibility policies. Solano County WIC program will continue to conduct the QA plan, and participate with the CDPH/WIC PMVs. Responsible Individual(s): Christopher Husing, Senior Health Services Manager, Solano Public Health Anticipated Completion Date: April 1, 2025

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Medicaid Cluster Federal Assistance Listing Number: 93.778 Pass‐through: California Department of Health Care Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County agrees that eligibility determinations and redeterminations including obtaining documentation and verifications should be performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. There are overdue redeterminations in our system due to the Medi-Cal expansion and increasing need for IHSS services in our communities without a substantial increase in staffing to support this service need. This year, we continue to have uncovered caseloads related to Social Worker job transition or leave, fair hearing and the growing complexity of our client population requiring more case management throughout the year. In FY 2024-25, we were granted seven additional social workers. We are anticipating these additional social workers will reduce the number of overdue redeterminations. We also have hired two Extra Help Social Workers who will focus on overdue redeterminations. We participate in State level discussions related to advocacy and increased IHSS administrative funding to support the growing number of IHSS clients. Responsible Individual(s): Gwendolyn Gill, Health Services Administrator Bela Matyas, Chief Deputy Director Anticipated Completion Date: July 1, 2025

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: CW 2.1: Solano County has policies and procedures as well as systematic processes set up to ensure the required collection and documentation of the applicant’s intent to cooperate with child support. It is Solano County’s policy that the Child Support Questionnaire (CW 2.1Q) and Notice and Agreement (CW2.1NA) be processed in accordance with regulations, which require workers to: • Conduct an interview either via telephone, or in-person with the applicant, print the forms, and document the County Use Section which requires worker’s signature and date. • Mail the forms to the applicant for a wet signature or collect the signature via electronic means. • Ensure the CW2.1 forms are received and complete. • Initiate the required case action(s) based upon information provided on the forms. Solano County has a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent this error in the future: • A post-Audit meeting will be held with all stakeholders to discuss the specific audit findings and action steps needed. • The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the applicable eligibility handbook with verbiage to emphasize the following: o The requirement to review and collect the information needed to complete the notice and agreement (form CW2.1) for child, spousal, and medical support from the applicant. o That the case be authorized according to program rules only after required forms are received by the county, reviewed to ensure that the case is updated with the correct information, documented in the case journal, and the form(s) scanned into the document imaging system. o Highlight these requirements when training this topic. • The CalWORKs Program Specialist will address the findings and requirements as follows: o Present at the Monthly Program Support Forum conducted with managers, supervisors, and lead workers. o Written guidance and reminder will be published in the Monthly Program Support Newsletter to all staff. o Present and discuss this requirement with lead workers at the Lead Worker Coordination Meeting, and with supervisors at the Division Coordination Meeting. • In addition to regular case reviews, focused case reviews will be added to review for completion of the Notice and Agreement for Child, Spousal, and Medical Support (form CW 2.1). SAWS 2A SAR: Solano County has policies and procedures as well as systematic processes set up to ensure the worker has reviewed the Rights and Responsibilities (SAWS 2A SAR) with the applicant/recipient and obtain their signature. It is Solano County’s policy that the SAWS 2A SAR be processed at application and redetermination which require workers to: • Conduct an interview either via telephone, or in-person with the applicant, print the form, and document the worker’s signature and date. • Mail the form to the applicant for a wet signature or collect the signature via electronic means. • Ensure the completed form is on file prior to authorizing benefits. Solano County has a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent this error in the future: • A post-Audit meeting will be held with all stakeholders to discuss the specific audit findings and action steps needed. • The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the applicable eligibility handbook with verbiage to emphasize the following: o That the case be authorized according to program rules only after the signed SAWS 2A SAR form is received by the county, documented in the case journal, and the form(s) scanned into the document imaging system. o Highlight these requirements when training this topic. • The CalWORKs Program Specialist will address the finding and requirement in the following ways: o Present at the Monthly Program Support Forum conducted with managers, supervisors, and lead workers. o Written guidance and reminder will be published in the Monthly Program Support Newsletter to all staff. o Present and discuss this requirement with lead workers at the Lead Worker Coordination Meeting, and with supervisors at the Division Coordination Meeting. • In addition to regular case reviews, focused case reviews will be added to review for completion of the Rights and Responsibilities (SAWS 2A SAR). Responsible Individual(s): Daniel Horel, Employment and Eligibility Services Administrator Thomas West, Employment and Eligibility Services Manager Diana Hernandez, Employment and Eligibility Services Manager Jennifer Stephenson, Employment and Eligibility Services Manager Anticipated Completion Date: May 31, 2025

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Housing Voucher Cluster Federal Assistance Listing Number: 14.871, 14.879 Pass‐through: n/a – direct award Award No. and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: Since May 2022, the County has contacted multiple agencies trying to report through the FSRS system on the multiple Housing Voucher awards, with no success. The County’s assigned Housing and Urban Development (HUD) office is the San Francisco regional office. Per their director, “These are systems that we don’t work with in HUD PIH so I won’t be able to be of assistance relative to this.” The County is unable to complete FFATA reporting for reasons outside of the County’s control. Responsible Individual(s): James Bezek, Director of Resources Management Anticipated Completion Date: Because the corrective action is outside of the County’s control, we cannot determine an anticipated completion date.

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has expanded staffing and continues to provide ongoing training through NASFAA, NCASFAA, CFNC, and Ellucian. Roles and responsibilities are now clearly defined to ensure proper segregation of duties, and cross-training is underway to provide continuity during vacancies. These efforts support the implementation of enhanced internal controls and Title IV compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025

Student Financial Assistance Cluster - Assistance Listing No. No. 84.268 Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional staff, enhanced training efforts, and established a standard procedure to send loan exit counseling notifications to students at the end of each term, ensuring regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing and Section 8 Housing Choice Vouchers Programs to ensure that established internal control policies are being followed on a timely basis. Julio Marenco, Interim Executive Director, will be responsible to implement this corrective action by June 30, 2025.

Federal Award Finding: 2024-001 Material Weakness in Compliance and Internal Control over Reporting Name and Contact Person: Adrienne Gaines, Executive Director Corrective Action: WISH has evaluated and revised the processes and procedures regarding monitoring of grant reporting and deadlines, as well as the processes for maintaining records supporting all grant reports, submission details, and corresponding approvals. Management will appoint an individual to oversee this for each grant. Proposed Completion Date: June 30, 2025

The County will implement procedures to ensure suspension and debarment checks are performed for all vendors. The County will also provide direction to staff involved in the preparation on contracts to ensure compliance. The County commits to mitigate the risks associated with engaging vendors who may be ineligible for federal funding.

Views of Responsible Officials and Planned Corrective Action: While Quincy Asian Resources, Inc. concurs with the ultimate outcome identified in the finding, we want to emphasize our review indicates all transactions were handled with appropriate intent. The identified adjustments were primarily due to timing of personnel transitions on our accounting department. To further strengthen our financial reporting processes, we have subsequently hired a new controller with extensive nonprofit accounting experience. This addition to our team Views of Responsible Officials and Planned Corrective Action: While Quincy Asian Resources, Inc. concurs with the ultimate outcome identified in the finding regarding timesheet the identified documentation issues stemmed from procedural gaps in our timekeeping processes rather than any misuse of funds. Our internal review confirms employees dedicated appropriate time to grant activities, but our timecard reporting system did not adequately capture this effort due to: 1. Staff’s incomplete understanding of federal documentation requirements 2. Need for enhanced timesheet review protocols 3. Limitations of our current time tracking system To strengthen our processes, we are: 1. Implementing a new time tracking system better aligned with federal requirements 2. Providing comprehensive training to all employees on proper time reporting 3. Training supervisors on thorough timesheet review procedures 4. Enhancing our internal controls around time documentation These improvements will ensure our documentation fully supports the valuable grant-funded services we provide to the community

Finding 2024-004 - Procurement (Material Weakness) CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: No Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: No Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement policy must include not only policies for procurements, but also for documentation of solicitations, contracts activities. Planned Implementation Date: October 31, 2024 Responsible Persons: District Board, Umpqua Public Transit District

Finding 2024-003 – Fiscal Management (Material Weakness) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District, and potential refunding of reimbursements received. Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation for each report was not possible because original data was not relied upon by management, to complete the reports and reimbursement requests. Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned. Questioned Cost: No Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities in the form of refunds due to ODOT.  Repeat of a Prior-Year Finding: Yes Recommendation: The District should design and implement internal control policies and procedures for cash management, including fiscal management and financial reporting. Monitoring, information and communication control activities should also be designed and implemented as part of the effort the reduce the risk of continued matters of noncompliance related to cash management. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving these deficiencies has been offered by ODOT and accepted by the Board. Planned Implementation Date: October 31, 2024 Responsible Persons: District Board, Umpqua Public Transit District

Condition: During audit procedures, we noted expenditures were charged to the program via adjusting journal entry for which adequate supporting documentation could not be provided. Corrective Actions: Going forward, the Organization will implement procedures requiring supporting documentation for all journal entries made to the program to ensure that amount charged to the program are actual expenses/expenditure of the program. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: March 31, 2025

Condition: During the audit several adjusting journal entries were proposed. These entries would have a material effect on the financial statements if not proposed and recorded. Corrective Actions: Going forward, the Organization will implement procedures to perform a more comprehensive monthly closing, especially at year end, to ensure that all general ledger accounts are reviewed and reconciled to arrive at a complete and accurate set of books and records to be audited. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: March 31, 2025

Condition: During audit procedures, it was noted total reimbursements received exceeded expenditures. The Organization has charged costs to the program and received reimbursement; however, the products cost charged to the program had not been received prior to June 30, 2024. Corrective Actions: Going forward, the Organization will review all vouchers being charged to the program to make sure costs have been incurred before being charged to the program. Employee Responsible for Corrective Action: Michelle Clarke Completion Date: March 31, 2025