Corrective Action Plans

StartUpNV, Inc. Corrective Action Plan Year Ended December 31, 2023 2023-001 System of Internal Controls and Resulting Disclaimer of Opinion Criteria: The Internal Revenue Service (IRS) has defined a charitable organization as “organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, educational, or other specified purposes.” As a result of an entity being recognized as an exempt charitable organization, the nonprofit is entitled to favorable treatment(s) reserved for such entities (e.g., reduced taxation). Condition: The Organization was unable to produce sufficient appropriate audit evidence to support its assertion that revenues and expenditures related to StartUpNV, Inc. exclusive activities. Cause: The system of internal controls implemented by the Organization was not well-defined and did not contain appropriate segregation of duties amongst non-interested parties. Effect: The Organization was unable to provide sufficient appropriate audit evidence to support issuance and receipt of an unmodified audit opinion. This led to delays in the overall audit process resulting in late filing of the Data Collection Form to the Federal Audit Clearinghouse (FAC). Recommendation: We recommend management design and implement a system of internal controls whereby clear delineation between StartUpNV, Inc. activities and those of interested parties is supported. Further, we recommend that this system of internal controls be well documented and consistently applied. Risk assessment as it relates to general exempt organization compliance, as well as specific compliance related to federal award receipts, should be consistently performed by appropriate, competent personnel. With these systems in place, StartUpNV, Inc. will be better positioned to support regulatory expectations and requirements. Responsible official: Maggie Saling Title: Chief of Operations Email: maggie@startupnv.org Phone number: 805.302.1862 StartUpNV will create a policy document that shows procedures for internal control of expenditures that includes independent oversight. StartUpNV plans to contract with an outside party to perform an independent review and approval of expenditures prior to grant reimbursement requests and establish formal, documented procedures governing this process. Due to the recent resignation of the board treasurer, the incoming treasurer will assume oversight responsibility for this independent reviewer and budgetary and expenditure controls. The current Executive Director plans to announce his retirement from the non-profit organization – and announce a Board of Directors search process for his replacement. The appointment of a new Executive Director will address the requirements for the segregation of duties and independence. The Chief of Operations will provide guidance and support to the new Executive Director, ensuring a smooth transition of responsibilities through her planned retirement by the end of the year. The search and hiring process for a new Executive Director is anticipated to be completed within a timeline of 6 months.

CONDITION: The Regional Office of Education No. 39 did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. PLAN: The ROE management will provide close oversight for the timely submission of grant expenditures and performance reports. Checklist, due dates, and reminders are shared from the Regional Superintendent to the Business Office Manager and Program Directors. Management will review the grant report submissions in IWAS for accuracy and completion before approving and submitting to ISBE. ANTICIPATED DATE OF COMPLETION: Implemented January 2024 CONTACT PERSON: Jill Reedy, Regional Superintendent

2023-007 Assistance Listing No. 96.001 , 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Period of Performance lnternal controls over period of performance were not consistentlv performed Response: Of the five instances noted in the auditor's "Period of Performance" test work, we concur with four. With one of the sample items, however, we argue that since the service was invoiced on a State Fiscal Year, it was impractical to further split the invoice into the various appropriate Federal periods of performance, especially given the way those specific invoices are allocated between other shared program areas within our agency, etc. Corrective Action Plan: Our agency takes these findings seraously and will continue to evaluate ways of improving controls. At a minimum, it is our intent to increase and provide additional training to the staff overseeing and approving these types of transactions so that they can accurately apply transactions to the appropriate periods. This was something we had already begun (i.e. provrding additional guidance and training to stafD during the current fiscal year. So, we hope our agency is already on a corrective path. But, we will continue to push for more training in the immediate future and strive for improvement in all other aspects. We also think it is important to note that, of the findings identifled by the auditors related to "Period of Performance," those items were discovered out of a total sample size oI 120 items (i.e. 60 sample items related to thejr "Period of Performance" test work and 60 sample items related to "General Disbursements" test work). So, a slightly larger sample size than that of the 60 referenced in the auditor's schedule of flndings. Additionally, the auditor's sample appeared to selectively target the specific periods and transactions that would have been most susceptible to these types of potential errors. And, although we are not objecting to the way in which the sample was selected, we would.just point out that this approach of sample selection may not be truly reflective of a purely random sample covering all transactions across the entire fiscal year. Therefore, although we ultimately concur with the findings here, we do not necessarily believe these results paint the fairest picture on the overall effectiveness of our agency's controls across the more than '100,000 transactions that would have been processed during the period of audit for this program. Again, we take these findings seriously. But, based on the audit test work and results, we feel the controls we have in place are ultimately working adequately enough to mitigate the potential for material misstatements. Regardless, we will continue to monitor and evaluate our controls to help further reduce the risk of these types of issues moving forward. Planned completion date for corrective action plan: lmmediately. But, additional training for managers to be provided by September 30, 2024.

2023-008 Assistance Listing No. 96.001, 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Allowable Costs lnternal Controls gtver glant disbursements were not consistently performed Response: There is no disagreement with the audit finding. Corrective Action Plan: Item is isolated and immaterial. And, we feel effective controls are in place to mitigate the likelihood of this type of error. We have also, since, reached out to the vendor to redeem the $14 associated with this transaction. However, we will continue to monitor and reinforce, with our managers, the importance of being vigilant during their review and approval processes for this type of situatlon. Planned completion date for corrective action plan: lmmediately Name(s) of the contact person(s) responsible for corrective actions: Andy Salin Finance Director 601-853-5220.

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive Leadership meeting. All Grants and cooperative agreements must be filed with the fiscal department. All expenditures must be approved prior to purchase / payment with sign off from Executive Director or Director of Finance.

U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083 Management’s Response: During 2024, management worked with the Fire Department and Payroll to ensure only straight time was coded to this grant and no overtime was charged to this grant. This was a finding in 2022 but we were not aware until the audit was completed in 2024 there was an issue the existing payroll system was not flagging. This has been corrected in in 2024 and should not be a recurring issue. Views of Responsible Officials and Corrective Action: The reason for recurrence is the finding was communicated late in the prior year. Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Financial Reporting and Review Process Description of the Finding: BSEDC did not have a secondary review process over the required financial reporting to Federal EDA. The lack of a secondary review process allowed for errors and omissions to go undetected, thus resulting in omission of $3,614 of loan origination fee income and interest income from federal program income calculations. Planned Corrective Actions: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director have implemented processes for the Senior Director of Finance to perform a secondary review of the required reporting to Federal EDA before it is submitted. Timeline for Completion: BSEDC implemented the secondary review process in October 2024 with the completion and submission of the FY24 annual report to Federal EDA. Responsible Person or Party: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director are both responsible for ensuring that the secondary review is complete before submitting reporting to Federal EDA.

Finding No.: 2023-011 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Areas Area: Period of Performance Questioned Costs: $11,004 Views of Auditee and Corrective Actions: GDOE disagrees with condition 1 related to FY 2024 purchase orders (PO). GDOE PO 20240171 is a copy over of the third-party fiduciary agent (TPFA) PO 20230010 which was issued in December 2022, within the CG 21 period of performance. GDOE acknowledges that the re-issued GDOE purchase order was not timely processed, however the purchase order which encumbered the funds occurred in the appropriate performance period. Additionally, relative to payroll, FPD requests a list (i.e. Staffing Pattern) of all Federally funded personnel from HR. FPD distributes the list to CG Project Leads to validate and compare to the Federal Roster as approved in the Consolidated Grants (CG) Application. The list is updated to make any corrections necessary. Once validated by Project Leads and FPD, HR is given a memo requesting to change/correct the funding year to the new grant award. In GDOE’s Munis system, if the Human Resources (HR) employee salary records are not accurately updated, GDOE payroll will reflect dated pay tables until such time HR makes the appropriate updates based on project lead requests to update accounts to current grant year. GDOE recorded journal entries to transfer the improperly charged payroll expenditure to the appropriate grant year. Plan of action and completion date: The GDOE will perform a monthly review of all transactions to ensure charges are recorded in the appropriate grant year. Additionally, Grant Project Managers and Program Coordinators will work with the HR and Business Office any changes to accounts charged for federally funded payroll expenditures. IAO now provides an independent review of drawdown requests - a control that will help prevent liquidation after applicable period of performance Plan to monitor and responsible officials: Financial Affairs under the leadership of the Deputy of Finance and Administrative Services, Morgan W. Paul, and the GDOE Comptroller (vacant), will ensure an accountant is monitoring the expenditures of federal grants and the corresponding periods of performance and liquidation periods. Grant Project Managers and Federal Compliance review team will also provide timely communication for changes in grant year funding to HR relative to federal payroll.

Finding No.: 2023-009 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Period of Performance Questioned Costs: $80,983 Views of Auditee and Corrective Actions: GDOE agrees with Condition 1 questioned costs of $560. The questioned charges are related to TPFA purchase orders issued in fiscal year 2019, which falls outside of the period of performance. The expenditure for the 2019 purchase order was transferred from the TPFA Munis and recorded in the incorrect GDOE Munis account. GDOE disagrees with Condition 2 questioned costs of $18,041. In line with federal regulations, GDOE paid (liquidated) the obligations in question on January 4 and 26, 2024, which is before the liquidation end date of January 28, 2024.E&Y auditors are citing GDOE for the issued checks clearing the bank after the liquidation end date, however, liquidation occurs when the recipient draws funds from the grants management system and pays obligations and not specifically when checks clear the bank. GDOE agrees with Condition 2 $62,382 questioned costs. While GDOE Munis system has recorded expenses of $62,382 related to Special Education (SPED) obligations, funds were not drawn for these expenditures. In GDOE’s federal review process, drawdowns are reviewed in alignment with specific conditions for allowability and in compliance with period of performance timelines. The identified funds were not expended from SPED grants. To correct this reporting deficiency, GDOE will record journal entries to transfer the expenditures to appropriate funding sources. Similarly, GDOE improperly charged $3.1 million in payroll expenditures to SPED grants after the period of performance. Subsequently, GDOE corrected this finding by making the appropriate journal entries to transfer the improperly charged payroll expenditure to the appropriate grant year. Plan of action and completion date: The GDOE will perform a monthly review of all transactions to ensure charges are recorded in the appropriate grant year. Additionally, Grant Project Managers and Program Coordinators will timely communicate to the Human Resources and Business Office any changes to accounts charged for federally funded payroll expenditures. The IAO now provides an independent review of drawdown requests - a control that will help prevent liquidation after applicable period of performance Plan to monitor and responsible officials: Financial Affairs under the leadership of the Deputy of Finance and Administrative Services, Morgan W. Paul, and the GDOE Comptroller (vacant), will ensure an accountant is monitoring the expenditures of federal grants and the corresponding periods of performance and liquidation periods. Grant Project Managers and Federal Compliance review team will also provide timely communication for changes in grant year funding to HR relative to federal payroll.

Finding No.: 2023-007 Federal Agency: U.S. Department of the Interior Pass-Through Entity: Government of Guam AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $113,767 Views of Auditee and Corrective Actions: GDOE agrees with the finding. GDOE is in receipt of Department of Interior grants and manages said funds in coordination with BBMR and Guam Homeland Security. GDOE established projects that were allowable for the use of these funds on a reimbursement basis. In an effort to maximize federal funding, GDOE initiated a transfer of expenses which was tied to a purchase order in FY 2016. Plan of action and completion date: GDOE Financial Affairs has recorded an adjusting journal entry to record the expenditures under FY 2021 but will have to reclass the expenditure in to FY 2020. GDOE will assign an accountant to reconcile GDOE’s Department of Interior budget availability with BBMR and will monitor AS400 for proper recording of transactions. Plan to monitor and responsible officials: The Comptroller (vacant) will monitor on a quarterly basis expenditure from the Department of Interior grant and will prepare a progress report on a semi-annual basis to the Deputy of Finance and Administrative Services, Morgan W. Paul, for review and approval.

The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.

The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.

The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.

Assistance listing number and program name: 84.010 Title I Grants to Local Educational Agencies Agency: Arizona Department of Education (ADE) Name of contact person and title: Tim McCain, ADE Chief Financial Officer Chris Brown, ADE Business Officer of Education Programs Anticipated completion date: January 2025 Agency’s response: Concur • ADE is working on standardizing fiscal efficiency by adopting uniform guidelines that monitor obligations and expenditures. These guidelines outline available resources and determine allocation amounts within federal awards and earmark expiration dates within programs. • ADE is also working on standardizing how funds may be reallocated to ensure that no funds are at risk of reverting to USED. Specifically, school improvement funds are now also tracked as part of Title I allocation and reallocation process. This will ensure funds are earmarked and obligated in a timely fashion (i.e., in the period of performance). This item is planned to be completed by January 2025.

Assistance listing number and program name: 21.023 COVID-19 - Emergency Rental Assistance Program Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Leanna DeKing, DES Policy Planning Project Manager Anticipated completion date: June 30, 2025 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations as follows: The Department will ensure program costs are properly recorded in the financial system during the period of performance and only obligated costs are spent during the liquidation period. Closeout activities, such as direct administrative costs, will be obligated prior to the end of the award period and spent within the liquidation period, or 120 calendar days after the period of performance ends. The Department will allocate sufficient resources to perform essential grant closeout functions to help prevent inappropriate charges. The Department will also update existing grant closeout procedures to require a review and approval of grant expenditures during the liquidation period to ensure they are allowable and properly obligated prior to the period of performance end date.

Assistance listing number and program name: 21.023 COVID-19 - Emergency Rental Assistance Program Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Molly Bright, DES CCSD Assistant Director Anticipated completion date: June 30, 2025 Agency’s response: Concur The Department of Economic Security will address the audit recommendations as follows: The Department will prepare and retain detailed documentation including system reports, queries, screenshots, and other evidence supporting the program information being reported to the federal agency for each Emergency Rental Assistance Program (ERAP) award. DES will also abide by its policies and procedures to retain all records relating to federal awards for a period of 5 years after all the federal funds are expended. For future related programs with this requirement, the Department will develop and implement internal control policies and procedures that ensure systems properly display complete and accurate data on the federal reporting dashboard as instructed by the federal agency’s reporting guidelines. Additionally, these policies and provisions will ensure that any future ERAP award funding received by the Department will be separately reported to avoid commingling. Finally, the Department will require that ERAP personnel verify the reported program information to ensure all report element sections are complete and accurate, and that it matches the underlying benefits and financial systems data. The Department sunset the ERAP program on October 13th, 2023, due to an exhaustion of ERA 1 and ERA 2 funding.

Catholic Charities of Central and Northern Missouri agrees with this finding and as of July 1, 2024 has altered procedures so that invoices and documentation related to expenditure of federal funds are now scanned and attached to the accounting entry recording the payable.

Finding 2023-002: Internal Control Deficiency and Noncompliance over Activities Allowed/Allowable Costs Principles, Period of Performance Federal Grantor: United States Department of Health and Human Services Assistance Listing No.: 93.048 Summary of Finding: Management did not have adequately designed internal controls in place over expenses charged to the federal program. Management also did not consistently retain evidence to support the existence of certain expenditures and thus the expenses were not adequately documented. Corrective Action Plan: Internal controls were implemented in October 2023 following the 2022-01 finding, to ensure expenditures are appropriately reviewed and approved prior to entering into the expenditure or requesting reimbursement from the federal program. Documentation will be maintained to support that expenditures were reviewed for appropriate period of performance. Management will ensure all duties are appropriately segregated. In addition, following the October 2023 implementation, care will be taken to ensure that invoices for vendors using electronic invoicing systems will be downloaded in a timelier manner to ensure electronic invoices do not expire within those systems. Responsible Party: Sonja Landry, Executive Director Anticipated Completion Date: Completed October 2023

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