Corrective Action Plans

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Period of Performance Corrective Action Plan: The Agency will work with Federal Partners to determine allowability of these claims. Contact: Heather Arnold Anticipated Completion Date: 6/30/2025

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Period of Performance Corrective Action Plan: A validation will be added into the case management system (QE2) that prevents an obligation from being created in a federal fiscal year with a service start date in a previous federal fiscal year. Contact: Cathy Callaway Anticipated Completion Date: April 1, 2025

Management’s Response and Corrective Action Plan: Alpine Achievers Initiative acknowledges the finding and recommendation. Late submissions occurred due to delays on responses from the grantor. Management will be more proactive in documenting communication regarding Period Expense Reports (PERs) to ensure that, if they are submitted late, there is clear evidence of why and what date they were initially submitted. Management is now aware that the PER system only reflects the final submission date once approved, not the initial submission date. To address this, Alpine Achievers Initiative (AAI) will implement a process to document the initial submission date along with any backup documentation of delays, including communications with Serve Colorado or other relevant parties. Additionally, Serve Colorado has clarified that while timely submission of PERs is required, grantees who communicate a need for additional time by the 15th of the month are considered compliant. Serve Colorado also noted that, based on AAI’s history and previous communications, they would not consider this a finding or an indicator of poor performance. Moving forward, AAI will ensure that any anticipated delays are formally communicated to Serve Colorado before the due date and that records of these communications are retained for audit purposes. Contact and Completion Date: Megan Strauss (megan@alpineachievers.org) is the primary contact, and the Executive Director at Alpine Achievers Initiative The correction action is expected to be resolved before the end of the next fiscal year-end of July 31, 2025.

Condition: Costs were charged to the grants for payroll and related benefits earned prior to the start of the grant period. Corrective Action Planned: We had budgeted the full cost of one teacher and four teaching assistances in the IDEA 240 grant for 2024. The approval process for the grant took longer than expected, our intent was always to comply, but we do realize we should have waited for the approval to be in place prior to charging the costs of these employees to the grant. In the future we will wait for the approval process to be complete and will then charge the employees there. Anticipated Completion Date: July 1, 2025 Contact: Martin Anguelov, Chief Financial Officer for Nantucket Public Schools and Deb Gately, Director of Special Education for Nantucket Public Schools

Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Corrective Action Planned: The Sandwich Public Schools will implement the following procedures to ensure that the 120 liquidation finding doesn’t happen again. 1. We will make sure that all costs are liquidated within the 120 day window after the end of the grant period. 2. If we see we are approaching the 120 day limit on a certain expense, we will reach out to DESE to ask for an extension to the 120 day liquidation requirement. 3. We will add these procedures to our Federal Grant Manual so that all are aware of these requirements. Anticipated Completion Date: June 30, 2025 Contact: Michelle Austin, Director of Finance and Business Operations

Condition: There was no evidence of a system of internal control over the cash management requirements, including a written policy related to reimbursement of funds on a per-refugee basis. In addition, it was noted that reimbursement was requested prior to incurring expenses on a per-refugee basis. There were also refugee costs coded incorrectly within the general ledger. Planned Corrective Action: Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that individual refugee costs were coded to the correct general ledger account. Contact person responsible for corrective action: Linda P. Foster, CEO Anticipated Completion Date: Refugee ledger reconciliation process completed 2/1/2025 Policy approval and implementation to be completed by 5/1/2025

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Material Weakness Summary of Finding: There is no administrate review of reimbursable expenses submitted to MAESSU by the district payroll clerks. Lack of an internal control. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Clerk will submit the reimbursement requests to the corporation Business Manager for review before the reimbursement is submitted to MAESSU for payment. Anticipated Completion Date: The anticipated completion date will be with the April reimbursement submission.

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Illinois Office of Emergency Management Federal Financial Assistance Listing #97.036 Program Name: Disaster Grants – Public Assistance Finding Summary: The Cooperative did not retain documentation to support the review and approval over material costs claimed for reimbursement under the program. Responsible Individuals: Scott Seipel (Warehouseman), Ryan Ruppel (Superintendent) Corrective Action Plan: A line or lines will be added to the material charge out sheet to formalize the review and approval. The Superintendent of Operations will begin reviewing and approving all material charge out sheets and documenting that review to supplement the review currently being done by the Warehouseman when entering the material charge out sheets prepared by other employees or contractors. Anticipated Completion Date: We believe this corrective action plan can be reasonably incorporated into our internal controls by June 2025 and will make necessary arrangements to ensure that it does get incorporated.

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. The department will monitor expenses within the budget and grant period based on guidance from the federal agency to ensure that the date of expenditures are not claimed before grant funds are received. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. To address this, the department will run quarterly reports from AWARE to identify any payments charged to the incorrect period of performance. Grant guidance has been updated to ensure items with unique service dates are properly reviewed. Additionally, during the three-month liquidation period, a monthly review of all expenditures will be conducted to verify they are applied to the correct period of performance. These actions will strengthen oversight and ensure compliance with grant requirements. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024

Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. We have updated our grant award templates to include all required information. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This has already been implemented effective 2/1/2025.

State Treasurer’s Office Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that our grant award template did not make subrecipients aware of all required grant award information for the Mineral Leasing Act as required. The Office of State Treasurer will review and update its grant award templates to ensure that subrecipients are made aware of all required grant award information. Contact Person: Nicole Krivoruchka, Director of Finance Anticipated Completion Date: December 31, 2025

A.    DESE has informed us that if this situation ever comes up in the future, asking for a federal extension if buses were not going to be delivered in a timely manner, in this case by January 10, 2025. The manufacturer assured us that the buses would be delivered by November 4, 2024 so we didn’t asked for the extension.

B.     In the future, we will wait until buses are on site to write checks.

C.     We do not anticipate any ESSER ARP money to be issued in the near future.

Management’s Response: The Human Resources (HR) team of the Chief Human Resources Officer and the HR Generalists are responsible for completing background checks for existing new employees. The HR team will ensure proper and required background checks are completed, reviewed and approved for all new and existing employees. Proper documentation and results of all background checks will be reviewed and filed accordingly. Estimated Completion Date: September 30, 2025 Responsible Position: Brent Wauneka, Chief Financial Officer; Ronnye Etsitty, Chief Human Resources Officer; and Chasity Jones and Vivian Upshaw, Human Resources Generalists

3.1.Ensure that the inventory expenses charged to the federal program are allowable within the period of performance. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

2.1 Ensure timely reconciliation of inventory distributions in order to record the transactions in the correct accounting period. Responsible Official: Head of Operations, Supply Chain Managers, DRD Operations, SCM RTAs, Completion Date: September 30, 2025

SINGLE AUDIT CORRECTIVE ACTION PLAN For the Fiscal Year Ended June 30, 2024 To Government Officials: SINGLE AUDIT FINDINGS: Finding 2024-001 Period of Performance Description of Finding Community Development Block Grant – Entitlement (ALN 14.218) funds must be expended by the end of the eighth fiscal year after the fiscal year of appropriation the combined effect is to provide an expenditure period of eight fiscal years from the fiscal year of appropriation. For award B-17-MC-09-0007 (CDBG 2017), the eighth year after the year of appropriation ended on June 30, 2024. On this date, amount left unexpended after the end of the period of performance was $17,814. Statement of Concurrence or Nonconcurrence Management agrees with this finding. Corrective Action We recommend that the City review processes and controls related to timeliness of CDBG expenditures to ensure they comply with federal award requirements. Projected Completion Date June 30, 2025 Name of Contact Person Joseph Feest, Economic Development Director

Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition: Kansas Division of Emergency Management (Management) did not issue subawards to subrecipients until after the fiscal year ended. Recommendation: We recommend that Management reviews and enhances its internal controls and procedures to ensure that subawards are issued timely to subrecipients, and that subawards include all required federal award information. Views of responsible officials: Management partially agrees with this finding. Although the 2023 2 CFR § 200.332 does state that the award letters should be sent at the time of the award, there needs to be some reasonableness to the interpretation of this regulation. KDEM currently has 13 open disasters with over 100 open projects and more being written. It is not reasonable to interpret that the award letters be sent on the date that the award is granted. Action taken in response to finding: Management will utilize the report run for FFATA to send award letters to sub-recipients. Name(s) of the contact person(s) responsible for corrective action: Jennifer Deal, Fiscal & Grants Management Section Chief Planned completion date for corrective action plan: Ongoing

Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. From review of the expense population, we noted 2 payments to the service provider where the service provider was not paid until after liquidation date of December 29, 2023. The School Corporation did not pay the service provider until April 30, 2024 for $258,488 for the services provided. Contact Person Responsible for Corrective Action: Abigail Lindsey Contact Phone Number: 765-853-5464 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Corporation will have all Special Ed funds paid before liquidation date. Anticipated Completion Date: 12/29/25

Corrective Action: More than one person has been given access to the portal to upload financial reports in case of turnover or other unforeseen circumstances. Person Responsible: Melinda Graham, Director of Finance Timing for Implementation: Effective October 1, 2024

Finding 2024-001 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Identification of the federal program: Federal Grantor: United States Department of Treasury Assistance Listing No.: 21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds Pass-Through Grantor: Michigan Health & Hospital Association Ascension Ministry Market: Michigan Pass-Through Award Number: SLFRP0127 Pass-Through Award Period: 12/01/2021-09/30/2023 Views of responsible officials: Ascension will reinforce the importance of timely approval of timecards for those participating in grant activities. For this grant, Ascension was allowed to identify eligible expenditures retrospectively; thus, grant-specific approval processes were not performed. All expenditures submitted for reimbursement were validated for adherence to the terms and conditions of the award. Responsible Official: Rob Madsen, Director of Accounting and Reporting, Grants & Research Anticipated completion date: May 1, 2025

Finding Number: 2024-002 Program Name/Assistance Listing Titles: Title I Grants to Local Educational Agencies; Education Stabilization Fund Assistance Listing Numbers: 84.010; 84.425U; 84.425W Contact Person: Kris Terwilleger, Director of Finance Anticipated Completion Date: June 30, 2025 Planned Corrective Action: Will adjust process of JE approval to include contingency plan that in the event of the accountant being absent, the Senior Buyer will prepare the JE for Director of Finance approval.

Auditor Description of Condition and Effect. This condition was caused by a lack of detailed review of the Return to Title IV calculation and days used in the Spring 2024 semester. As a result, four students' Return to Title IV calculations were performed using incorrect start dates for the 2024 Spring semester resulting in an understatement in $84 of Pell awards to the students. The College corrected this issue with the Department of Education on July 30, 2024. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of days used in the Return to Title IV calculation is accurate and that the Return to Title IV calculation is being reviewed by a second individual. Corrective Action. The College has performed the necessary steps to correct the error and will develop a process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. April 30, 2025.