Corrective Action Plans

U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/24/22 - 1/6/23, which the first eight days were prior to the start of the period of performance. There was also one transaction selected for testing where no supporting documentation was able to be located and one transaction that was incurred after the period of performance for the program. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Organization expanded contract compliance to include financial contract compliance. The organization will also implement grant tracking and spend management modules in the accounting software to assist with monitoring expenses applied to contracts. A new process will also be implemented regarding payroll related expenses to ensure the correct period is used for federal expenditures. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

COVID-1 9 Coronavirus State and Local Fiscal Recovery Funds — Assistance Listing No. 21 .027 Recommendation: We recommend the District design controls to ensure an adequate review process over the invoices recorded and presented on the schedule of expenditures of federal awards to determine compliance with the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District’s policies will be updated and approved if needed to conform to federal guidance. Name(s) of the contact person(s) responsible for corrective action: Ron McEachern, General Manager or Delia Stoor, Accounting Manger Planned completion date for corrective action plan: September 30, 2024

Finding Number: 2023-002 Planned Corrective Action: The Chief Financial Administrator will ensure all ARPA expenditures are included on the Project and Expenditure Reports. Anticipated Completion Date: March 31, 2025 Responsible Contact Person: Ben Cowdery, Chief Financial Administrator

Recommendation: We recommend that management ensure that internal controls are in place and operating effectively for period of performance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent a recurrence of the issue, we began implementing a corrective action plan. Specifically, we are enhancing our internal controls and began developing a comprehensive technical procedure manual that will serve as a detailed guide that provides a clear reference for finance and accounting staff to ensure consistency, compliance and efficiency in financial operations. Additionally, as SHRA is filling vacancies due to significant turnover across the entire Finance Department, specific training is provided to new employees in the following areas: • Building HOME • Capital Fund • CDBG • Continuum of Care • Developing a Cost Allocation Plan • Financial Management Part I and Part II (for CPD programs) • HCV Two Year Tool • IDIS • Mainstream Vouchers • Overview of Asset Management • PHA Financial Management Name(s) of the contact person(s) responsible for corrective action: Irene De Jong, DIRECTOR OF FINANCE Planned completion date for corrective action plan: December 31, 2025

We will implement several key improvements to enhance our compliance and reporting processes. We will utilize new software to automate the preparation and compilation of audit and compliance reports, streamlining workflows and reducing the risk of delays. Additionally, we are establishing a centralized document management system with strong retention and access protocols to ensure all relevant documentation is properly maintained and readily accessible. As part of this process, we will improve our procedures for identifying and aligning expenses with the appropriate grants to ensure accurate reporting and proper use of funds.

Recommendation: We recommend the Center review its contracts against the criteria set forth in the Uniform Guidance to ensure that all sub-awards in the future contain the required information for subrecipients. Action Taken: Tri-County 010 has taken the following corrective steps: Reviewed and Updated the Subrecipient Contract Template to include all required elements as outlined in Pennsylvania Department of Education. Implemented a Pro-Award Contract Review Checklist to ensure each contract is verified for compliance prior to execution. Established a Documentation Process for storing all subrecipient agreements and related compliance materials in a centralized location. Anticipated Completion Date: March 31, 2025 Contact Person Responsible: Christina Johnson, Executive Director

Develop external reporting matrix/schedule and report it to the Board of Directors by March 2025

Develop external reporting matrix/schedule and report it to the Board of Directors by March 2025

The Sheriff’s Department separated from the individual that handled the grant funding as of the first of 2025. We have worked diligently to get these reports correct as of December 31, 2024.

The Sheriff’s Department separated from the individual that handled the grant funding as of the first of 2025. We have worked diligently to get these reports correct as of December 31, 2024. Municipal Court recognizes that Quarter 5 was not submitted timely to the grant authority. We have since implemented a policy for grant reporting that related to the only current open grant administered by Municipal Court Probation Department. Section F states that a similar reporting schedule be implemented for all future grants received by the Probation Department. We want to reiterate that when received for the entire calendar year 2023, expenditures from the Violence Reduction Grant that were reported to BCS matched the expenditures on the Expense Transaction Ledger provided by the Auditor’s Office. The discrepancy was solely related to quarterly reporting to BCS and was corrected in the following quarter after initial understatement. We have controls in place to ensure that all grants will be reported timely and accurately moving forward

Finding 2023-003 The reporting package and data collection form for the 2022 audit was not filed by the September 30, 2023 deadline. This is a repeat of Finding 2022-001 from the 2022 audit. Auditors’ Recommendation NCST should ensure that its records are completed and reconciled in a timely manner, so that the single audit can be performed and completed on time, and the reporting package and data collection form can be submitted before the deadline. Corrective Action Taken To prevent future delays, NCST has streamlined financial reporting and established a timeline for federal and grant audit compliance. A Finance Director with extensive nonprofit experience has been hired, and a third-party accounting firm has been contracted for ongoing oversight, improved audit preparedness, and enhanced reporting accuracy. All financial reports are now being prepared and submitted by the deadlines, with continuous support and oversight by the third-party accounting firm and our internal Finance Director. Audit reconciliation and financial compliance processes have been significantly strengthened to ensure future deadlines are met without delay. Responsible Individual Executive Director, Rey Chavis Anticipated Completion Date March 2025.

The City will update amounts and descriptions within the Department of Treasury’s reporting portal to ensure all amounts expended are properly reported and proper revenue loss amounts are recognized.

Condition: Controls did not identify that expenses submitted to the State were outside of the period of performance. Planned Corrective Action: Background: Sinai began the process of risk assessment in the government grants area at the end of 2022. At that time, Sinai engaged outside counsel to assist in this process. In December of 2023, Sinai created the Office of Government Grant Administration (OGGA) and developed a comprehensive grant compliance policy and procedure. The Audit and Compliance Committee of the Board was updated on this initiative. In 2024, the OGGA created a Grant Compliance Manual which sets forth processes and procedures in grant management to ensure compliance with government regulations. Unfortunately, these controls were not implemented until after the relevant time period at issue in this audit. In 2025, Sinai is continuing to improve its compliance procedures with respect to government grants, and has developed the following plan: 1. Working Group: Sinai will implement a process of convening a Working Group for each government grant, which will consist of a representative from Finance, the OGGA, and the stakeholder involved (i.e., nursing, medicine, etc.) The Working group will be responsible for, among other things, ensuring that that the reported qualifying expenditures are incurred during the period of performance of the grant. In other words, allowable costs will be discussed early in the process, so that there is fulsome understanding among the key individuals involved. 2. Record-Keeping: The OGGA will also establish shared folders to house all of the pertinent documentation relative to the grant. 3. Invoice/Supporting Documentation Review. The Grant Accounting Manager will review all invoices and other supportive documentation to ensure that allowable costs are submitted for reimbursement. This compliance check will be completed prior to submission of the documentation for reimbursement. Monthly reviews of these activities will be performed by the Grant Accountant, the Compliance Grant Manager, and other OGGA staff as needed. Proactive review to prevent or resolve issues in the upcoming month’s billings should be pursued. 4. Annual Assessment. The Chief Compliance Officer, with the assistance of the General Counsel, will meet with the OGGA team annually to assess procedures and risk controls; a report of this assessment will be made to the Audit and Compliance Committee of the Board of Directors Contact person responsible for corrective action: Dimas Ortega - Vice President of Finance, Deputy Chief Financial Officer Anticipated Completion Date: 06/30/2025

Finding No.: 2023-029 Period of Performance Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director (DPHSS) The agency agrees with the finding and will apply the recommendations moving forward.

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

This was an oversight and has been corrected.

Expenses Supported with Required Documentation Contact Persons Responsible for the Corrective Action Plan: Tiana Pyles, Board Chair, and Arissa Palmer, Board Treasurer Corrective Action Plan: We agree with the finding and management has implemented tracking measures to ensure supporting documentation is maintained for grant-related expenses. Anticipated Completion Date: March 31, 2025

Expenses Reported in Proper Period Contact Persons Responsible for the Corrective Action Plan: Tiana Pyles, Board Chair, and Arissa Palmer, Board Treasurer Corrective Action Plan: We agree with the finding and have implemented an internal tracking system to monitor employee’s professional development allowance and ensure expenses are recorded in the proper period. Anticipated Completion Date: March 31, 2025

FA 2023-004 Strengthen Controls over Financial Reporting Compliance Requirement: Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.010 - Title I Grants to Local Educational Agencies Federal Award Number: SO10A210010 (Year: 2022) SO10A220010 (Year: 2023) Questioned Costs: $84,283 Repeat of Prior Year Finding: FA 2022-004, FA 2021-002, FA 2019-002 Description: The School District did not file accurate completion reports for the Title I Grants to Local Educational Agencies program. Corrective Action Plans: District office has put procedures in action to make sure that all drawdowns are in line with expenditures. All draw down packets will be viewed and signed off by federal program director. This packet will include detail expenditure sheet for the month, year to date expenditure report and a cover sheet. Estimated Completion Date: December 31, 2024 Contact Person: Torrence H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

FA 2023-001 Improve Controls over Financial Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Prior Year Finding: None Description: The accounting procedures of the School District were insufficient to provide adequate internal controls over multiple control categories. Corrective Action Plans: Management will review, design, and implement procedures to strengthen the internal controls over the accounting functions to ensure transactions are properly processed and reported. Estimated Completion Date: June 30, 2024 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131 extension 106 Email: daisy.prather@crawfordschools.org

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.