Corrective Action Plans

In 2023, TreePeople engaged an independent consulting firm to reconcile all accounts and perform month-end and year-end close activities. Also in 2023, TreePeople implemented new policies and procedures to support timely reporting – including new month-end and year-end close procedures. In 2024, TreePeople hired a new CFO and a new controller, bringing extensive non-profit finance and government grant management experience to the organization. The new CFO promptly implemented additional controls addressing month-end close activities and additional reviews and approvals of journal entries by the CFO and controller. The Accounts Receivable team, which previously reported to the programs team, will be reporting to the CFO starting December 1, 2024, to ensure timeliness and accuracy in charging of expenses, billing and revenue recognition for TreePeople’s government grants. Moving the Accounts Receivable team under the CFO's supervision will consolidate oversight and help strengthen our internal control process and assist in streamlining accounting and financial operations. To ensure expenses are coded to the proper federal program and spent within the allowable period of performance, the organization will leverage new accounting software to strengthen reconciliations and proper recording of revenue and expenses to the proper federal program in the proper period. All training and new processes will be updated and implemented by March 31, 2025.

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS agrees with the issues outlined, which stem from the delayed processing of invoices and untimely payments. These challenges are largely the result of longstanding issues with over-allocations and the need to catch up on processing a backlog of documents. We appreciate you bringing this to our attention, as it provides an opportunity to refine our procedures and put in place measures to prevent these issues from recurring in the future. This feedback will be valuable as we work to improve our processes and enhance our ability to manage workloads more effectively. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

Reporting Errors for the Coronavirus State and Local Recovery Funds were discovered. Reporting errors were unintentional and were a result of not more closely following the Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The employee who was responsible for entering the information into the portal is no longer with Allen County. New responsible staff will be trained appropriately according to the most currently released guidance and every effort will be made to ensure accuracy and complete reporting.

The Academy will ensure that only eligible expenses are included in the overhead calculation and that other rules and limitations are adhered to. The Academy increased the overhead rate to 10% default rate after learning of this overhead rule during the 2022 audit (mid-2023).

U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: BCHD will continue to work with the Department of Finance to ensure parameters for generating reports are the same and there is an agreed upon reconciliation when the parameters for reporting are not the same. Policies and procedures will be updated to ensure what is reported on Federal Financial Reports are reconciled to general ledger details in addition to ensuring all submitted reports have proper approvals documented. Accounting staff will be trained appropriately. Contact Person: Chief Financial Officer – Unyime Ekpa Completion Date: December 2024

2023-003: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures have been updated in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds)

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource 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 and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. Action Steps: 1. Communication a. Create Current Researcher Email List Serv for distribution of information/reminders. b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements. c. We will distribute information regarding this finding to our researchers every quarter via the listserv. d. Completion: The first distribution will occur on October 1, 2024 2. Develop Training Materials a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications. b. Include examples of compliant and non-compliant publications. c. Completion: Second Quarter of FY 2025 3. Campus-Wide Training a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method. b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project. c. Completion: Second Quarter of FY 2025 4. Award Specific Training a. 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. b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings. 5. Ongoing Monitoring and Compliance a. Maintain records of all training attendance. b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications. c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements. d. Non-compliant Faculty will not be able to submit proposals if training is delinquent. Anticipated Completion Date: June 30, 2025

Name of Responsible Individual: Konya White, Director of Enrollment Systems Associate Director for Compliance, Ben Carmichael, Associate Director for Compliance, and Roderick Johnson, Assistant Director for Compliance Corrective Action: This student’s Pell disbursement was not reported within 15 days of disbursement due to the COD (Common Origination Disbursement) system rejecting the student’s disbursement. These Pell rejects are worked through the reconciliation process and this exception was not worked in a timely manner, resulting in COD accepting the disbursement past the 15-day deadline. The Howard University employee who was completing reconciliation of Title IV funds, as well as responsible for working through any Pell rejected disbursements is no longer employed at Howard. The Assistant Director for Compliance works in the Office of Financial Aid and responsible for completing reconciliation and working any Pell rejected disbursements. The Associate Director for Compliance in Enrollment Management reviews reconciliations and ensures any rejected disbursements are resolved within the 15-day timeframe. Anticipated Completion Date: This finding was mitigated in May 2023. The responsibility of Title IV reconciliation was performed and worked by two consultants who had experience with Title IV reconciliation. The Assistant Director for Compliance hired in January 2024 has experience with Title IV reconciliation and was trained by the two consultants on Howard procedures for Title IV reconciliation and working rejected disbursements. The responsibility for Title IV reconciliation now lies entirely within the Office of Financial Aid.

Management agrees with the finding. The amendment in the Subrecipient Agreement to increase the grant awards from $50,000 to $150,000 resulted in new information provided by customers replacing in the Award Management Application’s, (Canopy), old information used in the original grant award. The bank established new procedures/requirements to avoid duplicate disbursements and/or confirm customers' bank accounts before processing transactions. All resources working on the CDBG-DR Small Business Financing (SBF) project have been trained to perform their role in accordance with the Program Guidelines, SOPs, and regulations. Cases identified with deficiencies, as part of the 2023 Single Audit at the Grant Awarding and Closing Stages, will be used as examples to prevent this situation from repeating in the future and to establish additional quality control (QC) by Team Leaders. Additionally, recapture (repayment by the Grantee of any Grant amount received) of awarded and disbursed funds will apply when there's failure to comply with the SBF Program Guidelines.

Corrective Action The exceptions were a result of review and approval documentation lacking certain information to identify non-recurring components of certain charges. In order to prevent this from reoccurring, the Agency will modify the current review, approval and payment documentation to specifically and clearly identify all components of each monthly payment separately, rent or subsidy amount, and any retroactive eligible amounts to be paid, along with a detailed explanation for any retroactive amount. This new protocol will clearly identify to the reviewer any and all adjustments from the appropriate expenditure amount that is being requested to be paid each month along with an explanation of the adjustment amount. By implementing this corrective action plan, we aim to prevent future deviations with respect to the recognition of expenditures in the proper period in accordance with contract terms. Individual Responsible for Corrective Action Plan Deborah Bordley, Controller 215-386-3838 Anticipated Completion Date: November 1, 2024

2023-006: Inadequate Documentation of Expense Approvals Corrective Action: The organization has since implemented additional controls to monitor expenses from government funding. The organization will implement a spending policy for federal funding and the organization uses expense tracking software and will implement regular approvals from program managers and directors of all federal expenses. Given the additional systems in place, we do not anticipate an issue with inadequate documentation of expense approvals and oversight moving forward.

1. Implementation of Sage Accounting Software: We have since implemented a comprehensive financial accounting software system, Sage, which allows us to track expenditures more accurately and ensure compliance with federal grant requirements. The system includes built-in safeguards to flag non-compliant expenditures.

2. Review and Strengthening of Internal Controls: Life Source International Charter School will be implementing additional internal control systems & processes that include an additional review of back up documents before monthly reports are filed. A copy of all backup documents in support of all monthly reports will be kept at both Life Source International Charter School and the outside entities providing services and making reports on behalf of Life Source International Charter School.

3. Staff Training and Capacity Building: Our staff has received training on federal grant compliance, including the specific criteria governing the period of performance and allowable costs under federal awards. Additionally, with the Sage system in place, staff are now better equipped to manage compliance and reporting accurately.

4. Commitment to Ongoing Compliance: We are committed to continually improving our internal control processes to ensure compliance with all federal regulations.

Finding Reference Number: 2023-003 Name of Responsible Person: Amy Reigel, Executive Director Reporting Views of Responsible Officials: We concur that there is no process in place to track that program income is expended prior to drawing on the federal grants. Concur or Do Not Concur with this Finding: Concur Agree or Disagree with Auditor Recommendations: Agree Completion Date or Proposed Completion Date: December 31, 2024 Actions Taken or Planned on this Finding: COHHIO's chart of accounts / financial management system will be updated to track the expenditure of program income in separate accounts.

Finding Reference Number: 2023-002 Name of Responsible Person: Amy Reigel, Executive Director Reporting Views of Responsible Officials: We concur that multiple grants are being tracked in the same accounts making it difficult to determine if the expenditures billed to the specific federal award to were charged to the grants in the period of performance. Concur or Do Not Concur with this Finding: Concur Agree or Disagree with Auditor Recommendations: Agree Completion Date or Proposed Completion Date: December 31, 2024 Actions Taken or Planned on this Finding: COHHIO's chart of accounts / financial management system will be updated to track each grant in a separately.

Management Response: We agree with the finding and will develop a corrective action plan.

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

Action taken in response to finding: The new CFO reviews and approves federal grant draw requests prior to the submission to the granting agency. Name(s) of the contact person(s) responsible for corrective action: Carrie Anthony Planned completion date for corrective action plan: August 31, 2024

Action taken in response to finding: The program experienced transition in management and staff during FY23. The new Recovery Support Services staff are now fully trained and ensures expenditures are incurred, charged appropriately and supporting documentation is maintained on file. Additionally, AP and Finance team review supporting documentation and ensure completeness. Name(s) of the contact person(s) responsible for corrective action: Floral Reed Planned completion date for corrective action plan: June 30, 2024

Action taken in response to finding: The Finance team corrected their processes to ensure proper recording of payroll costs during the time of the FY22 Audit procedures; however, the changes were made to subsequent months and previously submitted months were not retroactively corrected. Additionally, the OBHC team is currently working with the HCA in restructuring the rate schedule to incorporate the payroll costs into the direct service rates for the SOR/SABG grants. This effectively removes this issue going forward in FY25 once approved by the HCA. Name(s) of the contact person(s) responsible for corrective action: Carrie Anthony Planned completion date for corrective action plan: Sep 2023 & New rates: Sep 30, 2024

Action Taken: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

The subaward will be updated to include elements required by Uniform Guidance, Part 200.332.

1. Cleveland UMADAOP will obtain written prior approval for any expenditure deviations from the originally approved budget. This topic will be covered when training occurs during the quarterly review of grant guidelines. 2. As part of its updated financial policies and procedures, Cleveland UMADAOP will seek to document all financial activity to ensure compliance with grant and federal guidelines. 3. As part of the updated financial policies and procedures, Cleveland UMADAOP will seek written confirmation from funders whenever there is a deviation from the terms outlined in the original award documentation. 4. As part of the updated financial policies Cleveland UMADAOP will be using the services of a virtual accounting firm that specializes in: a) standardized monthly financial reporting packages that will be reconciled to the approved budgets; b) standardized monthly close processes that lock transactions at the end of each month; and c) electronic document retention for A/P and A/R among other services.