Corrective Action Plans

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.

Finding ref number: 2023-002 Finding caption: The Housing Authority had inadequate internal controls for ensuring compliance with the Housing Quality Standards enforcement requirements of its Housing Voucher Cluster program. Name, address, and telephone of Housing Authority contact person: Joanna Tepley, Finance Director 1555 S. Methow Street Wenatchee, WA 98801 (509) 663-7421 Corrective action the auditee plans to take in response to the finding: The HCV department will be creating an Excel spreadsheet for the inspector to complete and utilize to better manage compliance dates. It will include the failed inspection date, compliance due date, tenant and landlord names, passed date, abatement start date, and memos. In addition, the supervisor will be monitoring this spreadsheet and auditing inspection compliance more frequently. Anticipated date to complete the corrective action: Immediately

We appreciate the auditor's identification of the material weakness in our internal controls over the review of payroll registers for allowable costs and activities and period of performance related to our federal award. We understand the importance of maintaining effective internal controls to provide reasonable assurance that we are managing federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Documentation Process: We will implement a documentation process to ensure that payroll registers are reviewed for accuracy by management on a timely basis and that the review is properly documented. Specifically, we will: 1. Assign responsibility for reviewing payroll registers for accuracy by management to a specific staff member. 2. Establish a process for reviewing payroll registers for accuracy by management, including the use of a standardized form. 3. Ensure that all payroll registers related to our federal award are reviewed for accuracy by management on a timely basis and that the review is properly documented. 4. Investigate and resolve any discrepancies identified during the review process related to our federal award. 5. Document the review process related to our federal award and ensure that all documentation is properly maintained. Person Responsible: Anthony Jayesingha Date Corrected: 7/31/2023

2023-003 Internal Controls over Compliance and Compliance with the Period of Performance Compliance Requirement Contact: Sam Kimball Title:  Corporate Controller Phone Number: 202-296-9165 Estimated Completion Date – October 2024 Corrective Action: Management acknowledges the finding and notes that the costs identified related to a project that ended in March 2023. On October 1, 2023, the Foundation implemented a new ERP system that includes better controls around the period of performance, preventing transactions from being entered after the award end date and/or close out date, reducing the risk of recording transactions to projects outside of the stated period of performance. Therefore, management does not anticipate similar issues around period of performance going forward, as the risks are additionally addressed with the new system design.

The corrective action to be taken will be to created formal policies and procedures to ensure there is a second person involved in the reporting process. Expected Completion Date: December 31, 2024. Contact Person: Nicole McGee, Finance Director

Low-Income Home Energy Assistance Program (LIHEAP) – Assistance Listing No. 93.568 Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: County department personnel changes have been implemented which address this deficiency. New department personnel have been properly trained by County Auditor staff as well as State grantor personnel to ensure proper compliance with all program requirements regarding period of performance. Name(s) of the contact person(s) responsible for corrective action: Dave MacDonna, Director of Community Resources. Planned completion date for corrective action plan: July 1, 2024

Corrective Action Plan: The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions to NSC in June 2024. Files generated and submitted under the College’s new processes are taking roughly one week to process from initial submission, through error correction, and finalization. Contact Person(s): Justina Kirchgessner Anticipated Completion Date: End of 2024

Contact Person Responsible for Corrective Acton Plan: Debbie Nelson County AuditorCondition During testing, we note 1 material charge-out transaction where the item taken out of inventory was not supported with a signed requisition slip. Corrective Action Plan We agree. We will review the internal control process to verify all requisition slips get signed. Anticipated Completion Date Fiscal Year 2024