Corrective Action Plans

We concur with the auditor's recommendation to enhance internal controls, ensuring compliance with timely reporting as required by the grant agreements. Calendar reminders will be added to staff's calendars, and multiple levels will be notified of the reporting submissions.

2024-011 Oregon Health Authority Strengthen existing controls to ensure only those costs incurred during the period of performance are charged to the grant Management Response: The agency agrees with the finding. While the appropriate internal controls are in place to review the period of performance, a mistake was made while following the procedures. Secondary reviews will be performed going forward to ensure all expenditures are appropriately captured. The expenditures in question were moved to the correct phase 22 on Jan. 23, 2025 with document BTCG3186. Anticipated Completion Date: January 23, 2025 Contact Person: Travis Labrum, Accounting Manager

2024-029 Oregon Commission for the Blind Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with the recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate, and to ensuring the agency’s case management system is well-documented and current. This issue was initially identified during the statewide single audit for the period ended June 30, 2023. In response to the prior year’s finding, the agency created a new case-note category for documenting client employment start date and wages at exit. Compliance with this new control is then verified as part of our pre-closure case file review process. The agency will continue to provide training to staff on the use of this case note category to ensure we are consistently documenting the start date of employment in the primary occupation and the hourly wage at exit. Anticipated Completion Date: July 1, 2025 Contact person: Angel Hale, Director of Vocational Rehabilitation Services

2024-028 Oregon Department of Human Services Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with this recommendation. We agree with the recommendation and will ensure adequate supporting documentation is maintained and readily available to support information reported in the RSA-911. We will update internal controls related to this matter. Anticipated Completion Date: September 30, 2024 Contact Person: Bryan Campbell, Vocational Rehabilitation Operations Manager

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program from FY 2020 to FY 2024. We have identified the differences between our accounting records in SFMA and what has been recorded through IDIS, our portal to request funds from the federal government. As of March 2025, we are beginning to finalize our reconciliation of administrative funds and our own agency’s matching contributions. Once incorporating this first step, our accounting staff will continue with a full project reconciliation for the current fiscal year, 2025. Any errors or adjustments identified will be corrected in this current fiscal year. This reconciliation between accounting records in SFMA and IDIS is expected to be complete in May of 2025. Anticipated Completion Date: May 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

2024-042 Oregon Military Department Ensure payroll expenditures are coded to the correct period and errors are corrected timely Management Response: We agree with this recommendation. OMD acknowledges the finding regarding payroll expenditures coded outside the period of performance. We are committed to strengthening controls to ensure payroll expenses are properly recorded and errors are promptly corrected. OMD will implement following corrective actions to address the recommendation made in the Audit Report. • All Payroll Coding Review Procedures: Establish a mandatory review process before finalizing payroll reimbursement requests to verify the correct coding of federal fiscal year allocations. • Timely Error Correction Process: Develop a formal procedure to ensure errors are identified and corrected within 60-90 days of discovery. • Training and Oversight: Conduct mandatory training for finance and payroll personnel on proper coding procedures and compliance with federal performance periods. • Review and Correction of Prior Year Coding Errors (FFY 2019, 2022, and 2023): Conduct a comprehensive review of payroll expenditures from FFY 2019, 2022, and 2023 to identify and correct any remaining errors. This process will involve reconciling payroll records with federal grant periods, adjusting accounting records, and ensuring proper documentation for any necessary retroactive corrections. Anticipated completion date: January 31, 2026. Contact person: Adam Giblin, Chief Financial Officer.

2024-041 Oregon Military Department Ensure undisbursed obligation extension support is retained Management Response: We agree with this recommendation. The Oregon Military Department (OMD) acknowledges the finding related to the retention of support for undisbursed obligation extensions. We recognize the importance of maintaining documentation to support the extensions of General Terms and Conditions (GTC) Cooperative Agreement (CA) Awards to ensure compliance with federal regulations and avoid potential funding risks. OMD will implement following corrective actions to address the recommendation made in the Audit Report. • Standardized Documentation Process: We will develop and implement a standardized process for tracking and retaining all submitted GTA CA Award extensions, including detailed listings of un-cleared obligations and projected liquidation timelines. • Internal Review and Monitoring: A designated team within the finance division will conduct quarterly reviews of undisbursed obligations to ensure compliance with extension requirements. • Training and Accountability: Training will be provided to relevant personnel on the importance of documentation retention, compliance requirements, and the consequences of noncompliance. Management will also assign accountability measures to track adherence to the new procedures. Anticipated completion date: June 30, 2025. Contact person: Adam Giblin, Chief Financial Officer.

Harris County Public Health management acknowledges the requirements that each grant has a specified period of performance per the grant agreements of Federal awards. We also agree that failure to ensure expenses are properly reviewed and coded to the correct period or grant could result in noncompliance with the award contract, which may result in the early termination of the grant award, non-reimbursement of grant funding, or cessation of future funding. HCPH management will ensure that a detailed review of the period of performance is performed by grant staff by instituting staff training and reemphasizing the grant closeout process and procedures by September 2025

2024-011 Oregon Health Authority Strengthen existing controls to ensure only those costs incurred during the period of performance are charged to the grant Management Response: The agency agrees with the finding. While the appropriate internal controls are in place to review the period of performance, a mistake was made while following the procedures. Secondary reviews will be performed going forward to ensure all expenditures are appropriately captured. The expenditures in question were moved to the correct phase 22 on Jan. 23, 2025 with document BTCG3186. Anticipated Completion Date: January 23, 2025 Contact Person: Travis Labrum, Accounting Manager

2024-029 Oregon Commission for the Blind Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with the recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate, and to ensuring the agency’s case management system is well-documented and current. This issue was initially identified during the statewide single audit for the period ended June 30, 2023. In response to the prior year’s finding, the agency created a new case-note category for documenting client employment start date and wages at exit. Compliance with this new control is then verified as part of our pre-closure case file review process. The agency will continue to provide training to staff on the use of this case note category to ensure we are consistently documenting the start date of employment in the primary occupation and the hourly wage at exit. Anticipated Completion Date: July 1, 2025 Contact person: Angel Hale, Director of Vocational Rehabilitation Services

2024-028 Oregon Department of Human Services Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with this recommendation. We agree with the recommendation and will ensure adequate supporting documentation is maintained and readily available to support information reported in the RSA-911. We will update internal controls related to this matter. Anticipated Completion Date: September 30, 2024 Contact Person: Bryan Campbell, Vocational Rehabilitation Operations Manager

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program from FY 2020 to FY 2024. We have identified the differences between our accounting records in SFMA and what has been recorded through IDIS, our portal to request funds from the federal government. As of March 2025, we are beginning to finalize our reconciliation of administrative funds and our own agency’s matching contributions. Once incorporating this first step, our accounting staff will continue with a full project reconciliation for the current fiscal year, 2025. Any errors or adjustments identified will be corrected in this current fiscal year. This reconciliation between accounting records in SFMA and IDIS is expected to be complete in May of 2025. Anticipated Completion Date: May 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

2024-042 Oregon Military Department Ensure payroll expenditures are coded to the correct period and errors are corrected timely Management Response: We agree with this recommendation. OMD acknowledges the finding regarding payroll expenditures coded outside the period of performance. We are committed to strengthening controls to ensure payroll expenses are properly recorded and errors are promptly corrected. OMD will implement following corrective actions to address the recommendation made in the Audit Report. • All Payroll Coding Review Procedures: Establish a mandatory review process before finalizing payroll reimbursement requests to verify the correct coding of federal fiscal year allocations. • Timely Error Correction Process: Develop a formal procedure to ensure errors are identified and corrected within 60-90 days of discovery. • Training and Oversight: Conduct mandatory training for finance and payroll personnel on proper coding procedures and compliance with federal performance periods. • Review and Correction of Prior Year Coding Errors (FFY 2019, 2022, and 2023): Conduct a comprehensive review of payroll expenditures from FFY 2019, 2022, and 2023 to identify and correct any remaining errors. This process will involve reconciling payroll records with federal grant periods, adjusting accounting records, and ensuring proper documentation for any necessary retroactive corrections. Anticipated completion date: January 31, 2026. Contact person: Adam Giblin, Chief Financial Officer.

2024-041 Oregon Military Department Ensure undisbursed obligation extension support is retained Management Response: We agree with this recommendation. The Oregon Military Department (OMD) acknowledges the finding related to the retention of support for undisbursed obligation extensions. We recognize the importance of maintaining documentation to support the extensions of General Terms and Conditions (GTC) Cooperative Agreement (CA) Awards to ensure compliance with federal regulations and avoid potential funding risks. OMD will implement following corrective actions to address the recommendation made in the Audit Report. • Standardized Documentation Process: We will develop and implement a standardized process for tracking and retaining all submitted GTA CA Award extensions, including detailed listings of un-cleared obligations and projected liquidation timelines. • Internal Review and Monitoring: A designated team within the finance division will conduct quarterly reviews of undisbursed obligations to ensure compliance with extension requirements. • Training and Accountability: Training will be provided to relevant personnel on the importance of documentation retention, compliance requirements, and the consequences of noncompliance. Management will also assign accountability measures to track adherence to the new procedures. Anticipated completion date: June 30, 2025. Contact person: Adam Giblin, Chief Financial Officer.

2024-003 – PERIOD OF PERFORMANCE Significant Deficiency Auditee’s Response and Planned Corrective Action This finding relates to Operations funding and FHA fundamentally disagrees with the finding. The obligations for Operations were obligated in a timely manner. eLOCCS demonstrates that FHA was FHA is creating a master Capital Fund tracking calendar reviewed monthly by the Finance Department. FHA is also consulting with HUD field office staff on upcoming CFP grant timelines to avoid future errors. Planned Implementation Date of Corrective Action: Immediate Person Responsible for Corrective Action: Bobbi Richards, Executive Director

Recommendation: Our auditors recommended the Organization update their method of allocating expenditures to federal awards based on invoice date to ensure the incurred date is within the proper period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review grant requirements and make sure that allowable costs are incurred and allocated to the grant within the grant period.

The YWCA will implement the following changes in its accounting procedures. 1. The Staff Accountant will review the period each expenditure is related to and record the invoice to the appropriate period when entering it into accounts payable. The month and year will be noted on the invoice. 2. The CFO will review the month and year noted by the Staff Accountant prior to entry into accounts payable.

Finding 2024-001 Condition: Costs were recorded for service periods prior to grant approval date. Corrective Action Planned: The district will implement controls to prevent the recording of costs for service periods prior to grant approval date by written guidance to all staff involved in federal grant funds. Please note, that the practice at question is not in violation of school committee policy as we have not made any expenditures outside that entity’s approval date. Anticipated Completion Date: By July 1, 2025 Contact: Ross Mulkerin, Director of Finance and Operations

Finding 2024-02: Indirect Costs (IDC) Views of Responsible Officials Management agrees with the finding and recommendations. Through the merger with Old Dominion University, additional controls have adopted around the processes and controls around the accuracy of the review over indirect costs calculation requirements. Corrective Action Plan Effective July 1, 2024, EVMS merged with ODU and the ODU Research Foundation became the fiscal and administrative agent for EVMS’s transferring sponsored programs on behalf of ODU. As per ODU’s Memorandum of Understanding (MOU) with the ODU Research Foundation, the ODU Research Foundation has policies and processes in place to manage how the indirect costs are calculated. The ODU Research Foundation uses its own system of internal controls for IDC calculation with no reliance on ODU systems for those processes and are audited separately. As a corrective action moving forward, ODU management will notify the ODU Research Foundation management of the audit findings, so they are aware of the internal control deficiencies. ODU will request the Research Foundation to provide a copy of their single audit report to monitor continued compliance with Uniform Guidance. The corrective action plan will be completed by March 31, 2025 and the contact person for this finding is Victoria Dean.

Finding 2024-002 Significant Deficiency and Noncompliance - Lack of Required Uniform Guidance Policies and Procedures Condition: The City did not update their federal policies and procedures to be in full compliance with Uniform Guidance. Anticipated Completion Date: September 30, 2025 Corrective Action: The City will implement a new policy document specifically for Uniform Grant Compliance to have one document to ensure compliance.

Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research; Robert Clark, Chief Audit & Compliance Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications. Anticipated Completion Date: June 30, 2025

2024-007. Refugee Grant Expenditures Charged Outside Award Period State Agency: Department of Workforce Services Federal Agency: Department of Health and Human Services The department will implement a more detailed and thorough review of transactions to ensure that costs are attributed to the applicable period of performance in which the work was performed, and expenses were incurred and will ensure that costs are subsequently charged to the corresponding grant award. Anticipated correction date: January 31, 2025 Responsible person: Nathan Harrison, Executive Finance Director, 801-808-0676

Finding 2024-002 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency) Criteria: Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared. Condition and Context: The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements. The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample. City’s Corrective Action Plan: The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project. Contact person responsible for corrective action: Michael Lima, Finance Director Anticipated completion date: June 30, 2025

Office of Management and Budget (0MB) AUDIT FINDINGS Federal Awards Findings: Finding Reference Number: 2024-001 Description of Finding: As per the Department of Health and Human Services, HRSA Notice of Award to the organization and the Construction Projects (HRSA-23-117) Program Guidance document issued by HRSA, HRSA requires award recipients to seek prior approval through the Electronic Handbook for all pre-award costs. The organization incurred pre-award costs under the award; however, such costs were not submitted to HRSA for prior approval and thus, prior approval was not obtained. Statement of Concurrence or Nonconcurrence: The Organization is in agreement with this audit finding. Corrective Action: All grantor award guidelines will be reviewed by the Director of lnnovation & Grants and the Senior Director of Development to ensure all compliance requirements are interpreted and understood the same. If there is not a consistent understanding, then the Chief Development Officer wiIl review the guidelines. Name of Contact Person: Christine Leiby CFO; Telephone number: 860-769-3839; Email address: Christine.Leiby@oakhillct.org. Projected Completion Date: If the Office of Management and Budget requires any additional information or has questions regarding this Plan, please call Christine Leiby at the telephone number listed above.

View of Responsible Officials - The questioned costs were immaterial and relate to a pay period that was split across the fiscal year (6/26/23 to 7/9/23, with a pay date of 7/14/23). Reports to the funder for the year ending 6/30/23 were due on 7/10/23, before all payroll information and supporting documentation for this pay period was available. Therefore, the full pay period was included in the July reimbursement report. This practice was approved by the funder and the funder will not seek to recoup out of period costs. Moving forward, the Organization will be more cognizant of accrual dates for payroll reporting and submit a true-up as needed to ensure that payroll costs are correctly allocated at the end of the fiscal year