Corrective Action Plans

Oversight of Internal Controls - Completeness and Existence of Federal Expenditures Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will implement a centralized, documented review process for all federal expenditure tracking. To address turnover-related gaps and avoid data inconsistency: o Internally prepared spreadsheets will be reconciled monthly and locked once reviewed o All federal award-related spreadsheets will be reviewed by a staff member other than the preparer o Changes to prior-year data will require approval and documentation o A documented checklist will be used for month-end reconciliations. Additionally, the Business Manager will oversee staff training on federal compliance requirements related to documentation and review processes.

Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will establish formal written policies and procedures for the preparation of the Schedule of Expenditures of Federal Awards (SEFA) in compliance with 2 CFR 200.51 0(a). These procedures will: o Identify all sources of federal revenue o We have added the assigned federal funding source codes to our district budget operation in CSIU, which will now allow us to track these expenditures back to our internally controlled spreadsheets as verification of expenditures. o Track expenditures using dedicated account codes in the general ledger o Assign responsibility for monthly reconciliation and schedule preparation o Include a secondary review of the SEFA by someone other than the preparer The Business Office will undergo training on SEFA requirements and reconciliation practices. These changes will ensure complete and accurate reporting of federal expenditures for all future reporting periods.

FINDING 2024-003 Finding Subject: Title I Grants to Local Education Agencies - Special Tests and Provisions - Assessment System Contact Person Responsible for Corrective Action: Caleb Logan, Corporation Testing Coordinator Contact Phone Number and Email Address: (260) 367-3677 caleb.logan@whitko.org . Views of Responsible Official: We concur with this finding. Summary of Finding: School Corporation is required to obtain and store the completed Indiana Testing Security and Integrity Agreements for the entire staff. The School Corporation Testing Coordinator is responsible to gather all completed forms from each building for all staff and to store them. The Corporation Testing Coordinator during this audit period was a former employee of the School Corporation. The files of the Indiana Testing Security and Integrity Agreements were unable to be located from the former Testing Coordinator’s files (electronic or printed). The School Corporation had a process with the distribution, completion, and storage of the Indiana Testing Security and Integrity Agreements. However, there was ineffective internal controls and additional oversight in place to prevent these files from being recovered. Description of Corrective Action Plan: At the Beginning of each school year, the Testing Coordinator will distribute the Indiana Testing Security and Integrity Agreements to all staff through each Building Administrator. Employee completed agreements will be returned to the Building Administrator. Each Building Administrator will store these agreements for their building, and in turn will provide a copy to the School Corporation Testing Coordinator. The Testing Coordinator will verify that all staff have completed the agreement with a staff check sheet. The Corporation Testing Coordinator will follow up with any employee who has not completed an agreement. Staff hired during the school year are required to complete the agreement as well. The Testing Coordinator has both a hard paper copy as well as a scanned pdf file saved for all the completed agreements. At the end of the school year, the hard copy of all employees along with the check sheet will be stored in the central office secured storage room. Anticipated Completion Date: Immediately

Findings and Questioned Costs Relating to Federal Awards: Energy Incentive Program Disbursement to Ineligible Providers and Beneficiaries. Similar to prior year finding 2023-003, the program “Apoyo Energético”, funded by the American Rescue Plan Act (ARPA), that resulted in this finding concluded early 2023, which lack of a complete and robust operational guidance. The guidance used to manage the process were simple, not quite restrictive, and with little internal controls for both suppliers and beneficiaries. DDEC has adopted guidelines for both suppliers and beneficiaries that are more restrictive, and specific with internal regulations that ensure data retention and storage. A second initiative of this program, being “Apoyo Energético 2.0” commenced April 2024, which is funded by a CDBG-DR funds, for registration of potential suppliers and are following the guidelines issued. No findings were noted related to this program for which controls were enhanced, as a result corrective actions related to the 2023 finding.

Finding 2024-007 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: The Corporation Treasurer will review the Financial report more closely and make sure that internal controls are in place to ensure compliance. Anticipated Completion Date: March 2025

Finding 2024-005 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will implement internal controls that will correct the Allowable Activities and Costs procedures for Federal Grants. Anticipated Completion Date: March 2025

Finding 2024-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of SY 24/25 when the High School Treasurer checks the 10% of the paper applications, she will make a list of the ones she checked and it will be located in the application binder. As of March 1st, 2025 The Food Service Director will run a copy of Direct Certs that Titan has in their file, she will then cross check it with the list that is send from IDOE. She will keep both list together in a file after initialing it. Anticipated completion Date: March 2025

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.