Corrective Action Plans

Audit Finding Reference: 2024-003 Improve Controls and Documentation over Payroll Process Planned Corrective Action: Halfway through FY24, the District implemented a new payroll system, ADP. Since onboarding, it has become apparent that the "crosswalk" between ADP account codes and Munis codes is not adequate for the complexity in reporting for many of the District's federal and state awards. As ADP is a highly customizable platform, the Payroll and Finance team are in the process of designing a structure for seamless integration between running payroll and posting payroll to Munis, and ultimately charging those costs to grant awards. While this is occurring, the accounting team will review and reconcile payroll as possible in alignment with budgeted grant expenses. Name of Contact Person: Lesa Beck, Senior Payroll Manager Heather Peters, Accounting Manager Anticipated Completion Date: 6/30/2025

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: Whitley County Consolidated Schools Todd Fleetwood Director of Business and Operations INDIANA STATE BOARD OF ACCOUNTS 21 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com The School Corporation concurs with the finding. Description of Corrective Action Plan: The business office inadvertently omitted the reviewer’s sign-off on one of the grant reimbursement forms. This oversight will be promptly corrected. Anticipated Completion Date: 04/01/2025

Finding 2024-004 - U.S. Department of Education (USDE) - Higher Education Institutional Aid (Title III Programs) (Material weaknesses and Significant deficiencies): A. We observed the following questioned cost of $505,004 during our testing of Title III and Future Grant drawdowns (material weaknesses): a) Adequate supporting source documents and general ledger data was not readily on file to support three (3) of eleven drawdowns tested. The University subsequently supplied adjusting journal entries to reclass expenditures previously recorded elsewhere in the general ledger. However, the total amount of the questioned cost noted above was not substantiated, resulting in excess federal cash on hand. b) We noted two (2) drawdowns for payroll were drawn 20 days and nine (9) days before the actual payroll dates. B. Our testing of Title III cash disbursements revealed questioned cost of $55,525 as stated below (significant deficiency): a) Adequate supporting source documents, such as invoices, check request, and evidence of approval were not on file or provided for one (1) of eight (8) disbursements tested. b) One (1) check contained only one signature. C. We noted the following during our review of budget versus actual reporting. a) The University did not properly and accurately maintain budget vs actual schedules to adequately validate carryover and remaining balances. The budgets for Title Ill, Future grants appear to have been overspent; however, the reasonableness of under or over prior year remaining balances could not accurately be determined. D. We noted the following during our testing of time and effort reporting (significant deficiencies): a) The University subsequently provided corrected Time and Effort Reports for nine (9) out of 12 tested which we noted were previously missing employee signatures, signatures of approval by supervisor or next level of authority, salary distribution percentages, and grant funding codes. b) Personnel Action Forms originally provided for three (3) of four (4) employees tested did not contain salary allocations as evidence that salaries were to be allocated to the program. The University subsequently corrected the forms. c) The University also provided adjusting entries to reclassify salaries that were incorrectly recorded in the general ledger; however, we were unable to trace the salary distribution to the general ledger for two (2) of 12 tested. Auditor's Recommendation – 1) We recommend all drawdowns are approved by management prior to the request being made and reviewed to assure that drawdowns and supporting expenditures are accurately and timely recorded. Federal regulations require that funds drawn down are limited to the minimum amounts needed to cover immediate project cost and not made to cover future or budgeted expenditures. 2) We recommend the University require prior approval for all disbursements, including credit card, check, wires, and electronic funds transfer, and maintain supporting source documents in a manner that’s easily accessible when needed. Proper supporting source documents include invoices, approved expense/check request, payment advice copy, etc. 3) We recommend the University implement procedures for budget versus actual reporting to include allowable carryover budgets to accurately reflect remaining balances and to assure that the University is operating within the constraints of the grant budgets. 4) We recommend that the University maintain adequate supporting source documentation as evidence that time and effort reporting is accurately completed, reviewed and approved prior to seeking reimbursement for payroll expenses from the grantor. Federal regulations require that grant recipients provide reasonable assurance that charges are accurate, allowable, and properly allocated and that salary and wages charged to federal awards are based on actual rather than budget estimates. Corrective Action – The Vice President for Fiscal Affairs has implemented standard operating procedures to ensure the following: drawdown review and approval, centralize location for all grant related documents, award letters, invoices, etc. with accessibility for both Business Office and Sponsored Programs, and grant reconciliation completion date. The SOP will be included in the update Business Office Procedure document that will completed this fiscal year. The items identified in the 23-24 audit for grant were also contributed to the down-time of the ERP as well as having a new team in Sponsored Programs and Business Office reviewing and restoring the accounting records while trying to ensure accuracy and integrity in the recording of transactions. The institution disagrees with in-adequate approval of documents. The ERP is designed to not process purchase orders without appropriate approvals. All requisitions are approved by the area Vice President with any transactions $10,000 and over requires the signature of the President.

FINDING 2024-003 (Auditor Assigned Reference Number) Finding Subject: TRIO - Reporting Contact Person Responsible for Corrective Action: Nichole Stitt, AVP Sponsored Programs Contact Phone Number and Email Address: 317-921-4800 ext. 084987 and nstitt@ivytech.edu Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The college will develop an internal control system to ensure compliance with the requirement related to the TRIO reporting compliance requirement. Anticipated Completion Date: The projected date of completion for the CAP mentioned above is June 30, 2025. The Student Support Services APR process was corrected in April 2024, a query interfacing with Banner to identify errors in the APRs submitted by each campus, was created.

FFATA Reporting Prior Year Finding: 2023-004 Recommendation: We recommend the City establish procedures and internal controls to ensure that all required sub awards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each sub award. Explanation of disagreement with audit finding: NO Action taken in response to finding: Review City’s policy, procedures, and internal controls to ensure the required sub awards and reported timely and accurately to FSRS. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Crimer, Patrick Fletcher, & Kyera Pope. Planned completion date for corrective action plan: 06/30/25

YCIPTA will make the proper journal entries within QuickBooks to reflect the bus purchase properly.

To: Laura Sitrin, Director of Finance, Town of Falmouth From: Paul Dart, Director of Finance & Operations Date: March 31, 2025 RE: IDEA 240 Grant Expenditures The following outlines the findings, resolution and ongoing corrective actions for the IDEA FY24 Grant and FY25 Grant. Findings: Federal Award Findings and Questioned Costs 2024-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Resolution: The following corrective actions have been taken to immediately address this finding and ensure compliance with federal procurement regulations going forward: ● Journal entries have been submitted to the Town Accountant in order to move all FY24 expenses originally charged to the FY24 240 IDEA grant to either the School Choice Contracted Services account or Circuit Breaker Contracted Services account, as appropriate. ● A grant amendment is in process to reallocate funds in the FY24 240 grant originally intended for these specialized vendors to out of district tuition instead, ensuring compliance with procurement requirements. ● In addition to the above corrective actions related to the FY24 grant spending, any expenses for goods and services incurred in FY25 that did not meet federal procurement requirements have been corrected for FY24 grants that remain open. ● Grant amendments and journal entries for the FY25 240 grant and FY25 262 grant are in process for the current fiscal year to maintain compliance. These actions resolve the issue in the current fiscal year for all grants that are currently open. To strengthen internal controls and prevent recurrence, the Business Office is updating the District procurement policies and procedures to ensure the most restrictive procurement provision is followed for all purchases made with federal funds. All procurement and grant management staff have met to review training on the federal procurement process including thresholds, methods, documentation/justification for non-competitive procurements, and the differences between state and federal regulations. The district is committed to ensuring continued compliance through ongoing staff training, monitoring and policy updates. For further information or questions regarding this corrective action plan, please do not hesitate to contact me.

2024-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Division of Information Technology will implement a comprehensive user account deactivation procedure. The user account deactivation procedure will significantly reduce security risks, ensure compliance with regulatory requirements, and protect sensitive information from unauthorized access. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Network Services, Russell Weaver & Vice President / CIO, Darrell McMillon Planned completion date for corrective action plan: June 2025

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the National Student Loan Data System (NSLDS). The Registrar’s Office will continue to work with the National Student Clearinghouse (NSCL) and National Student Loan Data System (NSLDS) on the specific enrollment submission scenarios that require a different submission/update requirement. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: December 2025

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 7,2025 Planned Corrective Action: WUSD2 has designed and implemented an effective internal control procedure to ensure that the federal reporting is tracked and completed in a timely manner. The Business Manager and Federal Programs Director will meet monthly to review grant funding and reporting. This will include any deadlines for submissions of grants and reporting.

Contact Person NAME: Julia Delgado PHONE: (503) 280-2600 E-Mail: jdelgado@ulpdx.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned The Urban League of Portland is committed to an environment of continuous improvement. Further training shall be provided to Program Managers regarding the organizations’ documented internal controls and the importance of adhering to the established approval process. Urban League has currently hired a seasoned Controller and is in the process of hiring an experienced Accounting Manager. Tracking expiring grants more thoroughly and having further reviews in place to assure transactions are recorded within the grant’s agreed upon period of performance shall provide confidence expenses are recorded properly. Anticipated Completion Date: 05/01/2024

2024-003 H. Period of Performance Timely Payment of Financial Obligations Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendations. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue to educate all grant managers on (1) the reporting capabilities within the system that can be utilized in the execution of monitoring payment status on individual invoices that have been submitted to granting agencies for reimbursement, and (2) the requirement to use their grant specific general ledger coding when orders are placed with vendors that are set up under the Corporation’s group purchasing process. For the specific vendor noted in Finding 2024-003, a grant number input field has been added to the group purchasing orders to allow for enhanced tracking and review of expenditures associated with grants and the monitoring of payment of those expenditures. The use of the accurate grant general ledger coding by grant managers when orders are placed, will reduce the time between placement of order and payment of the invoice. Additionally, management will develop a federal grant policy that covers all requirements for compliance and internal controls for federal grants. The grant manager responsible for oversight of BHSB grants will work with BHSB to remedy the period of performance noncompliance noted in Finding 2024-003. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Housing Voucher Cluster – Assistance Listing Numbers 14.871/14.879 Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Views of responsible officials: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management commits to re-review applicable CFR and Admin Polices to assure we are starting from a good foundation and adjust HQS and Abatement processes as needed to assure compliance. Management to provide refresher process training on HQS Re-Inspection and Abatement timelines and documentation required to be in OnBase. No later than May 2025, SC Housing is restructuring the HCV department. This realignment will result in a dedicated inspection team that is not burdened with ancillary administrative tasks that have contributed to their inability to meet critical deadlines. Additionally, inspectors will have the flexibility to inspect 4-5 days per week as necessary. One of the key inspectors is physically located in the Low Country area which will minimize the travel time required to inspect in this region. Additionally, two of the employees associated with these errors are scheduled to be reassigned and will not be conducting on-site inspections in the future. Name(s) of the contact person(s) responsible for corrective action: Lisa Wilkerson, Director of Rental Assistance and Compliance Lenzy Morris, Director of HCVP Operations Planned completion date for corrective action plan: Restructure in planned for late April, initial training will begin immediately and continue as needed.

Housing Voucher Cluster – Assistance Listing Numbers 14.871/14.879 Compliance Requirement: Special Tests and Provisions – Housing Quality Standards (HQS) Inspections Recommendation: We recommend the Authority implements controls to ensure that required HQS are completed timely. Views of responsible officials: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management commits to re-review applicable CFR and Admin Polices to assure we are starting from a good foundation and adjust HQS processes as needed to bring all HQS inspections into compliance. Management to provide refresher process training on HQS expected timelines and documentation required to be in OnBase. No later than May 2025, SC Housing is restructuring the HCV department. This realignment will result in a dedicated inspection team that is not burdened with ancillary administrative tasks that have contributed to their inability to meet critical deadlines. Additionally, inspectors will have the flexibility to inspect 4-5 days per week as necessary. One of the key inspectors is physically located in the Low Country area which will minimize the travel time required to inspect in this region. Two of the inspections with findings were in a portfolio assigned to an employee exhibiting substandard performance who was subsequently terminated. These cases have been reassigned. Name(s) of the contact person(s) responsible for corrective action: Lisa Wilkerson, Director of Rental Assistance and Compliance Lenzy Morris, Director of HCVP Operations Planned completion date for corrective action plan: Restructure in planned for late April, initial training will begin immediately and continue as needed.

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies included within the Plan are being followed. Karen Raugh, Executive Director, is responsible for implementing this corrective action by June 30, 2025.

FINDING 2024-006 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Shelly Leifer Contact Phone Number and Email Address: 260.306.3359 shelly_leifer@mcs.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The comptroller will reach out to the IDOE regarding the dates required for submission. The comptroller, with the curriculum director, will populate the spreadsheet. The comptroller will get a signature from the assistant superintendent or superintendent before submittal. Anticipated Completion Date: March 31, 2025

The District has undergone training regarding the Davis-Bacon Act and will now adhere to its requirements when federal funds are utilized for construction projects. This includes compliance with contracts, specifically incorporating prevailing wage clauses and ensuring that federal wage rates and fringe benefits are met through a diligent monitoring process. This process involves the collection and review of weekly certified payroll reports from contractors or subcontractors. The District will also ensure that all information pertaining to the Davis-Bacon Act is displayed at the job site to maintain compliance. Furthermore, all accounting and management personnel will participate in annual training to remain informed about the Davis-Bacon Act's requirements. All actions are scheduled to be completed by June 30, 2025.

The accounting staff and management responsible for coding within the District will consistently oversee and conduct monthly edit checks in the accounting software to assess all expenses and confirm their coding accuracy. These monthly checks will help identify any coding mistakes in the Oklahoma Cost Accounting System, ensuring that expenses are thoroughly reviewed and corrected as necessary. Any inquiries or issues regarding coding will be addressed in collaboration with the Oklahoma State Department of Education and/or school auditors to confirm the appropriate coding options. Monthly spreadsheets have been developed and will be submitted to the Superintendent for evaluation following the reconciliation of claims related to Federal expenditures. The Expenditures of Federal Awards will match the numbers submitted to the Oklahoma Cost Accounting System. Additionally, encumbrances will be examined at the end of the year and will be closed if found to be inaccurate. All actions will be corrected by June 30, 2025.

Special Tests and Provisions Health Centers Cluster – Assistance Listing No. 93.224 and 93.527 Recommendation: We recommend the Organization implement a comprehensive and thorough process to review all patient information received, prior to it being entered into the system to ensure proper classification of the sliding fee scale. As part of this, the Organization should ensure the accuracy and completeness of the patient information prior to entering into the billing software. Management should work to conduct internal audits of patient visits to determine all required patient information has been obtained and properly entered into the system in accordance with the Organization’s sliding fee scale policy. Action taken in response to finding: A monthly internal audit of the sliding fee (HNP) will be implemented and as of April 1, 2025 to ensure accuracy of the documentation and calculations. Name(s) of the contact person(s) responsible for corrective action: Daria Sztaba, CFO Planned completion date for corrective action plan: April 1, 2025 and it will continue moving forward on a monthly basis.

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

FINDING 2024-003 Finding Subject: Child Nutrition Cluster- Eligibility Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business official or superintendent will review and sign off and date the eligibility reports. Anticipated Completion Date: September 30, 2025

Action taken in response to finding: • The Department has revised its internal policy and procedures to include timelines and a tracking mechanism to ensure the timely submission of fiscal reports and documents. Name(s) of the contact person(s) responsible for corrective action: • Anthony Walker, Associate Director of the Management Services Division • Anissa Curtis, Budget Analyst III for Aging and Disabilities Services Division Planned completion date for corrective action plan: • Items previously cited for submission have been updated and at this time the Department is in compliance with all fiscal reports. • Revisions to the internal Policy and Procedures have been corrected and disseminated to appropriate staff.

To ensure compliance with the 60-day enrollment update requirement, the Registrar's Office staff will manually enter any withdrawals and leaves of absence into the National Student Clearinghouse (NSC) website upon processing them in Coileague. Using the Student Look Up tool on the NSC website, they will update the student's status along with the status start date. Additionally, the confirmation email from the NSC, which verifies that the enrollment update has been processed, will be saved in the student's record.

The Department has completed its corrective action plan from the prior audit. DLPS has been in full compliance with the FFATA reporting requirement since August 2024. COMPLETION DATE/ CONTACT PERSON & PHONE# Fiscal Year 2024 and Ongoing Salvatore Marcello (609) 882-2000 ext.3046 Salvatore.Marcello@njsp.gov

The Department of Human Services, Division of Mental Health and Addiction Services (DMHAS) agrees that for fiscal year 2024 it did not complete Federal Funding Accountability & Transparency Act (FFATA) uploads timely. DMHAS maintains written FFATA policies and procedures, and it is compliant with its SSA SFY 2023 Corrective Action Plan (CAP) which included a January 1, 2025 implementation date. However, DMHAS was unable to comply timely with the FFATA reporting requirements due to competing reporting requirements, in conjunction with the volume of data and effort required. In addition to the significant progress DMHAS reported in the FY 2023 CAP update provided below, DMHAS accomplished the following: On October 21, 2024, DMHAS on boarded a full-time FFATA Analyst dedicated to FFATA data collection and uploads. On October 23 and October 29, 2024, DMHAS conducted training for the FFATA analyst. On or about January 29, 2025 and February 3, 2025, in an effort to demonstrate its proficiency and show its good faith efforts to comply, DMHAS uploaded all SUPTRS SFY23 and SFY24 Test Contracts (FAIN ending 5822) for the SSA SFY 2024. On or about February 3, 2025 and February 19, 2025, in an effort to demonstrate its proficiency and show its good faith efforts to comply, DMHAS uploaded all SOR SFY23 and SFY24 (FAIN ending 5743) Test Contracts for the SSA SFY24. Thereafter, DMHAS completed the following uploads: • February 27, 2025 – SOR FAIN ending 5743 – remaining contracts (outside of the SSA24 Test group) up to the FSRS ceiling (which limits data entry to forty (40) pages and UEIs. • March 4, 2025 – SUPTRS FAIN ending 7054 – all contracts uploaded. • March 6, 2025 – SOR FAIN ending 7774 – all contracts (into FSRS prior to migration) • March 6, 2025 – SUPTRS FAIN ending 5822 - remaining contracts (outside of the SSA24 Test group) up to the FSRS ceiling (which limits data entry to forty (40) pages and UEIs. On January 22, 2025, the DMHAS Compliance Quality Assurance Specialist who helps monitor FFATA compliance completed the federal SAM.gov training. On March 5, 2025, the DMHAS FFATA Analyst completed the federal SAM.gov training. DMHAS remains committed to FFATA compliance, is prioritizing FFATA reporting, and is making a good faith effort to comply. However, DMHAS notes various federal issues outside of the State’s control that are causing delays and increasing administrative burden. More specifically, uploads that predated the conversion from FSRS to Sam.gov were limited by a system error so DMHAS was precluded from entering all contracts/UEIs. In addition, FAINs are missing from SAM.gov, thus precluding the submission of the corresponding uploads. DMHAS is documenting the upload limitations and missing FAINs, along with its continued efforts to overcome the various obstacles outside of its control. COMPLETION DATE/ CONTACT PERSON & PHONE# January 1, 2025 John Fogliano, Deputy CFO (609) 438-4278 John.Fogliano@dhs.nj.gov