Corrective Action Plans

Block Grants for Prevention and Treatment of Substance Abuse - Assistance Listing No. 93.959 Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on accrual basis of accounting is presented during year-end training. The Department will participate in trainings offered by the County regarding the accrual basis of accounting for expenditures and will ensure accruals are properly captured within the proper period. Names of the contact persons responsible for corrective action: Aimee Espinoza, Auditor- Controller and Tarrah Shockley, Division Chief. Planned completion date for corrective action plan: June 30, 20

Block Grants for Community Mental Health Services - Assistance Listing No. 93.958 Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on accrual basis of accounting is presented during year-end training. As accruals are only recorded in the Financial Management System (FMS) on an annual basis department will have to manually accrue expenditures when charging other departments for costs incurred. The Aging and Adult Services Department will participate in trainings offered by the County regarding the accrual basis of accounting for expenditures and will ensure sure accruals are properly captured in the proper period when charging costs to BHRS. Names of the contact persons responsible for corrective action: Aimee Espinoza, Auditor- Controller and Tarrah Shockley, Division Chief. Planned completion date for corrective action plan: June 30, 2024

FINDING: 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The P&E report was prepared by one employee without an oversight or review process in place to ensure accuracy. The report submitted was not mathematically accurate or complete. Per Resolution 2022-1028, approved on December 12, 2022, the City obligated funds for six separate projects totaling $2,257,927. However, the P&E report submitted on April 18, 2023 only included one project resulting in an understatement of total obligations of $1,807,927. Additionally for the one project submitted the key line items of “Current Period Expenditures”, “Total Cumulative Expenditures”, and “Current Period Obligations” as reported on the P&E report did not agree to the City’s financial ledger Contact Person Responsible for Corrective Action: Lynn M. Gorski, Clerk-Treasurer Contact Phone Number: 574-936-2124 Views of Responsible Official: We concur with the finding from SBOA. Description of Corrective Action Plan: There was very little training on how to enter information into the Treasury website for the 2022 year. When it was entered there was only one obligation in the amount of $68,609 even though Resolution No. 2022-1028 noted the intent on spend. Because of lack of training on entering the information it was understated. When the information was entered for the April 2024 report all obligations were entered. When the next report is processed, I will have another staff member verify what is entered prior to submission to the Treasury Department. Anticipated Completion Date: April 30, 2025 Lynn M. Gorski Title: Clerk-Treasurer Date: August 26, 2024

FINDING 2023-006 Finding Subject: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds – US 12 Stormwater Drainage Improvement Project – Reporting Summary of Finding: The Michigan City Sanitary District did not design or implement a system of internal controls that would have prevented the omission of required progress reports, and lack of oversight process. Contact Person Responsible for Corrective Action: Mary Lynn Wall 219-873-1404 Ext 2006 Contact Phone Number and Email Address: 219-873-1404 Ext 2006 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Sanitary District will review the federal grant requirements in order to ensure required reports are submitted in a timely manner. Reports will also be reviewed and documented by another employee prior to submission. Anticipated Completion Date: 08/26/2024

FINDING 2023-004 Finding Subject: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds – Body Camera - Reporting Summary of Finding: The City did not design or implement a system of internal controls that would have prevented the omission of required progress reports, and lack of oversight process. Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 Ext. 2006 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The City department responsible for federal grant reporting will review the grant requirements in order to ensure required reports are submitted in a timely manner. Reports will also be reviewed and documented by another employee prior to submission. Anticipated Completion Date: 08/26/2024

FINDING 2023-003 Finding Subject: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds – Body Camera – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: The City entered into a grant agreement on 03/03/2023 for the purchase of body cameras. The invoice for the body cameras was dated 10/28/2022, prior to approval from the state. The purchase was outside the period of performance. Contact Person Responsible for Corrective Action: Mary Lynn Wall Contact Phone Number and Email Address: 219-873-1404 Ext. 2006 mlwall@emichigancity.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In order for the City to insure that internal controls are in place to prevent noncompliance with federal awards, the City Controller’s office will review and discuss with department personnel, all federal grant applications to ensure compliance with allowable costs and period of performance. Anticipated Completion Date: 08/26/2024

Finding 2023-03 Expenditure of Funds Outside Contract Period Condition: Testing revealed that the Organization claimed expenditures against the grant that occurred before the official grant period. Although these expenditures were made outside the period of performance, they were submitted for reimbursement without securing prior authorization from the pass-through entity. Corrective Actions Taken or Planned: The Organizations’ Board and Executive Team consisting of the Chief Executive Officer (CEO) and the Chief Operating Officer (COO) and key Overdose Lifeline (ODL) Staff to include the independent bookkeeper and Grant and Finance Manager recognize the need to enhance internal controls and mechanisms to ensure purchase do not occur outside grant periods.

Views of Responsible Officials Responsible/Contact Official Paul Barenfus, CLO, and Sylvia Sanchez, CFO Management Response The ERP Grant is a very different grant from previous grants received by the Credit Union. Although management followed the instructions provided on the CDFI website, it was not clear that running the loan through the ERP track for eligibility was only one of several steps. After auditors noted that 4 loans were ineligible, management searched the website to find the second track that the loans had to be qualified through, the Majority-Minority Census. The team has not had to qualify loans like this in the past, and the additional third step for qualification was not understood. Management has since replaced the unqualified loans on the 2023 SEFA with eligible loans. Documented procedures for the ERP Grant have been completed and are being followed. Anticipated Completion Date This item is complete.

VSS has hired and is onboarding and participating with YPTC with a timeline of the remainder of the current fiscal year (FY24) and the beginning of next fiscal year (FY25). YPTC’s scope of work will include evaluating, updating, and training on new finance policies and procedures to include but not limited to reviewing period of performance requirements.

Boston Fire Department (BFD) incorporated and implemented proper control procedures around all grant related matter; including but not limited to programmatic reporting and oversight. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

FINDING 2023-001 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The Kosciusko County Sheriff's Office applied for the Indiana Local Body Camera Grant (ILBC). The sheriff’s office was awarded this grant on January 1, 2023, with a grant cost amount of up to $31,920. This grant is a reimbursable grant through the Indiana Department of Homeland Security. The period of performance was from January 1, 2023, to December 31, 2023. The Kosciusko County Sheriff's Office ordered body-worn cameras and equipment on April 26, 2023. The invoice for the cameras and the camera equipment was paid on July 14, 2023. The Kosciusko County Sheriff's Office then submitted a Reimbursement Claim Form on September 11, 2023. The Reimbursement Claim Form shows the Sheriff's Office incorrectly requested the full $31,920. They received $31,920 from the Indiana Department of Homeland Security on September 27, 2023. However, the county had only spent $9,581 of the grant money towards the body camera purchase. Therefore, there is a remaining balance in the fund of $22,339 as of December 31, 2023. Due to the period of performance, the county should have reimbursed the Indiana Department of Homeland Security $22,339. On May 9, 2023, the Sheriff's Office grant administrator submitted a Program Report for the ILBC grant. This report was filed without an implemented internal control or evidence of a review. The report was completed and submitted by the Sheriff's Office grant administrator. The report incorrectly indicated that all expenditures had been completed. As of the date of the submission, the county had not purchased the bodyworn cameras and all federal funds had not been expended. Contact Person Responsible for Corrective Action: Alyssa Schmucker Contact Phone Number and Email Address: 574-372-2325 aschmucker@kosciusko.in.gov View of Responsible Officials: We concur with the findings identified. Description of Corrective Action Plan: The Kosciusko Sheriff’s Office, grant coordinator will contact IDHS for instruction on how to return the $22,339.00 and prepare a claim to be processed by the Kosciusko County Auditor’s office. The grant balances are submitted each month by departments these are checked and confirmed by the Auditor’s Office this one was overlooked in the review process. The person who applied for the grant no longer works for the county. It is believed the new person handling the grants was not aware that this grant even existed. The Grant Administrator(s) will have someone sign off on the grant report submissions and forward all reports to the Auditor’s Office. Anticipated Completion Date: It is anticipated that this will be completed as soon as the information to return the funds is received from the state and the claim is submitted to the Auditor for payment. This claim will be paid as soon as it is received. On or before 12/31/2024.

Finding 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: The County had not properly designated or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance. A single employee prepared and submitted reports without a documented review or oversight process in place to prevent or detect and correct errors. The County submitted three P&E reports during the audit period. No report was submitted for the period of October 1, 2022 to December 31, 2022 although there was activity during this time period. For the three reports submitted, all activity for the reporting period was not included and the reports were not fairly presented. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We are putting Internal Controls in place specific to the Covid-19 Coronavirus State and Local Fiscal Recovery Funds grant. We will put a checklist together when it is submitted by other departments with a review and approval process for the disbursement by the governing body before the claim can be processed. Anticipated Completion Date: October 2024

Federal Agency Name: Department of Homeland Security Pass-Through Entity: State of Nebraska Emergency Management Agency Federal Financial Assistance Listing #97.039 Program Name: Hazard Mitigation Grant Program Finding Summary: There was one instance of an employee’s timesheet which was reviewed and approved by the same employee and did not have an independent review performed. Responsible Individuals: Carmen Christensen, CFO/Office Manager Corrective Action Plan: The employee who reviews the timesheet is the general foreman. Action has been taken and all general foreman time will be approved electronically by the Operations Manager once training has been completed on entering time in the software system. Anticipated Completion Date: October 1, 2024

Significant Deficiency in Internal Controls over Compliance Condition: Final financial report revenues and expenditures were overstated in the Town’s general ledger. Corrective Action Planned: The School Business Office has implemented a process to reconcile grants funds by compiling the incoming payments for the schools department and sending the details, along with the correct account numbers for each payment to both the town treasurer and accountant. Review of general ledger will be completed when Final Financial Reports are filed to ensure accuracy in posting of revenues and expenditures. The School Business Manager will communicate with Town Accountant if discrepancies are discovered. Anticipated Completion Date: September 30, 2024 Contact: Liz Latoria, School Business Manager

Material Weakness in Internal Controls over Compliance Condition: Time and effort certifications were not maintained for grant employees’ whose salaries and wages were not supported by detailed time records. Corrective Action Planned: The School Business Office is working with the SPED department to implement a system for completion and maintenance of time and effort certifications for federally funded grants salaries, based on the recommendations of the Town auditors. Anticipated Completion Date: September 30, 2024 Contact: Liz Latoria, School Business Manager

Condition: Invoices were charged for services performed prior to the award approval dates by the pass-through agency. Corrective Action Planned: At the recommendation of the Town auditors, the business office keeps its own records of grant revenues and expenses and verifies the accuracy of those entered by the Town Accountant's office. These records also contain the period of performance for each grant, which has helped to ensure spending is kept within the correct dates. The School Business Manager reviews all requisitions for accuracy to verify expenses are being charged to the correct grants or funding sources. Anticipated Completion Date: Spring of 2024 Contact: Liz Latoria, School Business Manager

Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Corrective Action Planned: The School Department appointed a new School Business Manager in the Spring of 2024. The newly appointed School Business Manager has begun the process of closing out the overdue grants. Amendments as required have been completed and are awaiting DESE approval. Once approved, the School Business Manager will file final financial reports for all overdue grants. Anticipated Completion Date: September 1, 2024 Contact: Liz Latoria, School Business Manager

Name of Auditee: Amsterdam Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2023 CAP Prepared by: Damaris Carbone, Executive Director Phone: (518) 842-2894 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (1) Finding 2023-001 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action taken - The Authority will implement a comprehensive reporting calendar and tracking system, provide staff training on reporting requirements, establish an internal review and approval process for reports, conduct quarterly internal compliance audits, maintain regular communication with HUD, and continuously improve and document reporting processes with an annual review. These actions aim to ensure timely and accurate report submissions, thereby preventing future findings and maintaining eligibility for HUD funding. (c) Planned implementation date - The Authority plans to implement procedures during the fiscal year ending December 31, 2024 to resolve the reported finding.

Select Board and School Committee will adopt any required written policies and procedures under Uniform Guidance. Select Board and School Committee will formally adopt written policies and procedures under Uniform Guidance by September 30, 2024

Status: Corrective action in progress Corrective Action: The City agrees with the finding. HOST makes every effort to comply with all federal requirements. Starting with our 2020 ESG Award, HOST entered into 3-year contracts with our subrecipient providers within the outlined periods of performance (POP): E-20-MC-08-0005/AWD-00001006 (06/26/2020 – 06/25/2022) E-21-MC-08-0005/AWD-00001212 (07/26/2021 – 07/25/2023) E-22-MC-08-0005/AWD-00001376 (11/04/2022 – 11/03/2024) While the annual Federal awards indicated a 24-month POP from the date of the contract execution/IDIS obligation date, the subrecipient contracts were encumbered and executed within a calendar year POP and amended as necessary upon receipt of the annual award. As such, there was overlap in the eligibility dates. The $2,426.75 under SI-00629712 was for EMERGENCY Essential Services for August case management. SI-00629712 was for eligible expenses in August 2023. The expenses should have been expensed under the E22 award based on the Federal POP. Executing multiple-year contracts for annual grant awards was a pilot project with the goal of improving the process. HOST has determined that annual subrecipient awards accordant to our Federal award timeline is more supportive of our internal grant policies and procedures. The Division of Operations and Impact has established policies and procedures that guarantee appropriate internal controls are in place to ensure that eligible expenditures are within a grant’s period of performance. A non-exhaustive list of the established policies that illustrate this are listed below: ٠Managing the AP Inbox & Data Entry into Salesforce ٠HOST Accounts Payable Voucher Processing Aid ٠HOST Contract Invoice Process Map Person(s) Responsible for Implementing: Ami Webb, HOST Division of Operations & Impact Finance Director Implementation Date: Complete

FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Significant Deficiency Contact Person Responsible for Corrective Action: Ann Hathaway Contact Phone Number and Email Address: 317-852-1126 ahathaway@brownsburg.org Views of Responsible Officials: We concur with the finding that there was not a review in place prior to submitting the report for 3/31/2023. The rules, dates and requirements were quickly changing for the reporting of the Coronavirus State and Local Fiscal Recovery Funds. With there being only one project and a relatively small amount spent, the report was filed with no errors. Description of Corrective Action Plan: The 3/31/2024 report was reviewed and further reports will be going forward. Anticipated Completion Date: Immediately

FINDING 2023-002 Finding Subject: Covid-19 -Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the program invoices as required; however, there were no internal controls in place that would likely be e􀆯ective in preventing, or detecting and correcting, noncompliance related to the reporting requirements. The program invoices were prepared and submitted by one employee without oversight, review or approval. Contact person responsible for Corrective Action: Scott Wagner Contact phone number and email address: 260-248-3121 ext. 5, swagner@whitleygov.com View of responsible O􀆯icials: We concur with the findings. Description of corrective action plan: The Whitley County Health Department will develop and implement a policy that will establish and maintain e􀆯ective internal control for invoices for State and Federal Grants, received by the Department. The Director of the department will review all compiled data and sign the invoice along with the employee who compiled the invoice data. In cases where the Director is the employee compiling the data, the o􀆯ice administrator will also sign the invoice to verify the data is correct. Anticipation of completion date: immediately

The City will report revenue replacement dollars as the Auditor of State recommends.

ALN: 93.323, Corrective Action Plan: Controls and Compliance - ELC Subrecipient Disclosures - DPHHS - The Montana Department of Public Health and Human Services updated its contract template for the 2023 Epidemiology and Laboratory Capacity for Infectious Diseases program contracts to include all required disclosures. Controls have been implemented to properly classify subrecipient relationships and to ensure all federal award information is communicated. In addition, training was provided to division staff on various subrecipient requirements, including identification of subrecipient relationships and disclosures, in May 2024. The department also implemented detective and monitoring controls to ensure compliance. Person(s) Responsible for Corrective Measures: David Gerard, Executive Director, Montana Department of Public Health and Human Services, Target Date: Completed

ALN: 84.425, 84.425F, Corrective Action Plan: Controls and Compliance - HEERF - MSU - The Montana State University - Bozeman will enhance internal controls to comply with federal regulations surrounding cash management and reporting requirements for new Federal programs, including those through the Higher Education Emergency Relief Fund (HEERF), and intends to use existing resources and controls within the university to strengthen the review and reporting requirements for new programs. The university is corresponding with the United States Department of Education to resolve the use of outstanding HEERF monies. Person(s) Responsible for Corrective Measures: Aaron Mitchell, Associate Vice President for Financial Services, Montana State University - Bozeman, Target Date: 12/31/2024