Corrective Action Plans

Finding 2023-001 Name of Responsible Individual: Tonya Kilpatrick, AVP Finance and Compliance Corrective Action: We agree. The expenditures were reported on the schedule of expenditures for federal awards subsequent to the period of performance end date. These funds were not charged to the agency and are considered cost share for the grant as the work on the grant continued past the grant end date. We will review our grant close-out procedures to ensure that grants are closed out in a timely manner based on the grant end date preventing subsequent charges to the grant award. Anticipated Completion Date: March 1, 2024

Management’s response - In response to the finding indicated in the governance letter, management recognizes that the physical work performed for this expense occurred in FY23, but this is also an ongoing project and the period of performance for the ARP ESSER grant ends on 9/30/2024 not 6/30/23. Therefore, Management believes their interpretation is also correct. All federal and state grants with a period of performance ending 6/30/23 were accrued back to FY23 ensuring payments and receipts activities were in the correct time frame. Final reimbursement was requested, and the grants were closed out. The implementation of our new financial system also added an extra layer of complexity to our end of year accounting. Work in 2 different systems that do not work cohesively with each other was very challenging. We respect and appreciate the work of our auditors and understand that at times we will disagree and interpret things differently, which is what happened in regard to the expense for the HVAC project surrounding the "period of performance" language.

Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2023 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2023-002 (a) Comments on the Findings and Recommendations - 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 also agrees with the recommendation and will review all compliance requirements and HUD notifications for all new funding sources. (c) Planned Implementation Date - The Authority expects to complete the corrective action by March 31, 2024.

State Agency: Office of Children and Family Services Single Audit Contact: Bonnie Hahn Title: External Audit Liaison Telephone: 518-486-1034 E-mail Address: Bonnie.Hahn@ocfs.ny.gov Federal Program(s) (ALN # [s]): Rehabilitation Services-Vocational Rehabilitation Grants to States (84.126) Audit Report Reference: 2023-010 Anticipated Completion Date: January 15, 2024 Corrective Action Planned: New York State Commission for the Blind (NYSCB) is updating the Internal Controls and Data Validation policy for the RSA 911 report to implement an additional control to ensure the accuracy of the key elements including ‘Start date of Employment in Primary Occupation’ #350. The Senior Vocational Rehabilitation Counselor (VRC) will review the start date for employment during their review of cases when the Individualized Plan for Employment (IPE) is approved and at the time of successful closure. The Senior VRC will also verify that the employment start date is entered and accurate on the employment information form in the case management system. Training on this additional internal control will be provided to the Senior Vocational Rehabilitation Counselor’s and District Managers virtually on December 11, 2023. State Agency: State Education Department Single Audit Contact: Jeanne Day Title: Auditor 3 Telephone: 518-474-5919 E-mail Address: Jeanne.Day@nysed.gov Federal Program(s) (ALN # [s]): Rehabilitation Services - Vocational Rehabilitation Grants to States (84.126) Audit Report Reference: 2023-010 Anticipated Completion Date: December 2023 Corrective Action Planned: Adult Career and Continuing Education – Vocational Rehabilitation (ACCES-VR) will continue to implement and document review processes and methods. The implementation of the Aware electronic case management system is complete and will enhance the agency’s review process. A review process memo is currently in development related to Testing and will clearly document the scope and requirements associated with the review process.

Planned Action: The organization will review and revise all internal processes to ensure that there is proper accounting regarding this program and others. A review of policies and systems will be an important part of this process to ensure that only expenses incurred during the period of performance are billed to the grants.

2023-001 Cash Disbursement Review and Approval. BPC established its policies and procedures that included processes for proper approval of all transactions in September of 2023 during the audit for the previous year. The transactions without approval were all prior to the new policy and procedure. The organization continues to follow written policies and procedures for proper approval of all transactions posted in the general ledger.

Finding number: 2023-002; Finding: During our testing, we noted that internal controls were not properly designed over activities allowed or unallowed, allowable costs/cost principles and period of performance to identify program expenditures from other expenditures in the cost center. Additionally, we noted controls were not operating as designed to ensure payroll expenses charged to the program were properly approved. In our sample of 20 payroll expenditures, two had no evidence of timesheet approval. Correction actions taken or planned: Additional review and approval of allowable expenditures will be done by another individual outside of the preparer. Any payroll related dollars charged to the grant will require sign off by the manager prior to charging the expense to the grant. Anticipated completion Date: February 2024; UW Health employees responsible for Corrective Action Plan: Heather Brahm, Director of Finance & Controller, and Jamie Soyk, Program Director of Financial Reporting

Finding Number 2023-005 — Significant Deficiency in Internal Control/Non-Compliance — Appropriate Expense Period of Covid 19-ESSER II 23b — Credit Recovery Condition: During expense testing of ESSER funds, a journal entry that reclassed the cost of Edmentum, program licenses for Plato courses, had expensed the entire annual license fee. The period for eligible expenditures did not begin until October 1, 2022. This journal entry expensed the full cost of the invoice, $11,914.50, and the district did not prorate the costs to include only those expenses from October 1, 2022 through June 30, 2023. The District did not adhere to the proper period for expenditures. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop a summary of all federal grants. This summary will detail the fiscal year it is associated with but more importantly, it will provide the proper period of eligible expenditures for each federal funding source. This summary may be used and readily available at the time approvals are granted for expenditures. If an expense does not fall within the eligible time period, the expense can be rejected by the approver. This summary will be shared with all administrators and staff. In addition, the process for reclass journal entries will also include a pause to check that each invoice associated with a federal grant, is falling within the proper period of expenditures. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools

United States Department of Treasury Indiana Finance Authority, a Component Unit of the State of Indiana (IFA) submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Katz, Sapper & Miller, LLP 800 East 96th Street, Suite 500 Indianapolis, IN 46240 Audit period: Year ended June 30, 2023 The findings from the schedule of findings and questioned costs for the year ended June 30, 2023, are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FINANCIAL STATEMENT FINDINGS None FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Significant Deficiency in Internal Control over Compliance and Noncompliance – H. Period of Performance Recommendation: The Auditor recommended the IFA implement procedures to ensure the disbursement review process is operating effectively. Planned Corrective Actions: The Indiana Finance Authority (IFA) has procedures in place to assure the appropriate use of the federal funds the IFA manages. IFA oversight includes the robust review process of all disbursements which includes IFA engineers and finance staff. With respect to the matter your letter references, the IFA reviewed our existing Standard Operating Procedures and have edited them to reflect the date of the period of performance as part of the checklist for the program. The new IFA Program Manager has been updated on the procedures and the importance of being in compliant with the federal guidelines. The funds were corrected subsequent to year end and paid with operating revenues during fiscal year 2024. If the United States Department of Treasury has questions regarding this plan, please call Dan Huge, Public Finance Director of the State of Indiana at 317.233.4332.

See corrective action plan in audit report

Corrective Action Plan 2023-002: The University concurs with the finding and has provided corrective action through correcting the identified errors and adding additional review of the R2T4 calculations. Anticipated Completion Date: June 2023 Contact Person: Reta George, Director of Student Financial Services

Views of responsible officials and planned corrective actions: The Financial and Data Analytics Director conducts spot testing of each bi-weekly payroll expenditure report received from Human Resources for eligible PRF reporting. Evidence of testing is retained. Responsible Officials: Dean C. Cocchi, Vice President and CFO Completion Date: March 31, 2022

Finding No.: 2022-042 AL Program: 97.036 - Disaster Grants - Public Assistance (Presidentially Declared Disasters) Area: Period of Performance Questioned Costs: $423,234 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: Condition 1: 1. Regarding the finding related to DR4235MP, PW 95, the Public Assistance Office agrees that the liquidation was processed after the liquidation deadline. 2. Regarding the finding related to DR4396MP, PW 4, the Public Assistance Office disagrees with this finding. Liquidation was done prior to the closeout deadline of December 31, 2022. 3. Regarding the finding related to DR4511MP, PW 27, the Public Assistance Office disagrees with this finding. Liquidation was done prior to the closeout deadline of June 30, 2025. 4. Regarding the finding related to DR4511MP, PW 8, the Public Assistance Office disagrees with this finding. Liquidation was done prior to the closeout deadline of June 30, 2025. As of Fiscal Year 2024, the Public Assistance Office initiates drawdown requests, allowing for more timely processing. The office will implement better financial monitoring procedures to ensure obligations are liquidated within the required liquidation period. Staff will also be refreshed on liquidation requirements to ensure compliance. When delays are anticipated, the office will coordinate with subrecipients and promptly request necessary time extension approvals from Grantor to maintain compliance. Proposed Completion Date: Ongoing Condition 2: The Public Assistance Office respectfully disagrees with this finding. • Regarding the finding related to DR4235MP, PW 49, the Public Assistance Office disagrees with this finding. The invoice was dated and recorded after the period of performance (June 30, 2022), but date of actual work completed as shown on the Megger Test was May 20, 2022. The Public Assistance Office acknowledges that the record of the Megger Test had not been submitted to the auditors when submitting documentation. The Public Assistance Office will continue to exercise diligence in reviewing project documentation to ensure that all work is verified and completed prior to payment/reimbursement. The office will continue to monitor performance timelines to confirm that work is completed on or before the established period of performance deadlines. This process will include periodic internal reviews and coordination with subrecipients to ensure compliance. When delays are anticipated, the office will coordinate with subrecipients and promptly request necessary time extension approvals from Grantor to maintain compliance. Proposed Completion Date: Ongoing

Finding No.: 2022-035 AL Program: 93.767 - Children’s Health Insurance Program Area: Period of Performance Questioned Costs: $38,556 Contact Person(s): Geroge J. Cruz, Medicaid Director Corrective Action Plan: The CNMI Medicaid Office respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the office maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Proposed Completion Date: Ongoing

Finding No.: 2022-016 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $494,836 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (E. Cabrera): The Office of Grant Management (OGM) respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintain all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Based on our records, grant award D20AP00005 remains active with a period of performance extending through September 30, 2025, while grant award D20AP00037 was closed on September 30, 2024. Both grants remained operational well beyond the originally prescribed September 30, 2022 deadline. Given the extended period of performance authorized by the awarding agency, all associated questioned costs ($494,660.00) are supported by active grant activity and should be deemed allowable. Accordingly, OGM respectfully requests that these questioned costs be removed, as they reflect legitimate expenditures incurred within the approved grant periods. Proposed Completion Date: Ongoing Condition 2 (N. Karakaya): CIP agrees with the finding. To address the finding and prevent recurrence, CIP will: - Revise and strengthen written financial management policies to clearly define documentation requirements to substantiate expenditures and ensure costs are within the award’s period of performance. - Incorporate federal regulation references, including 2 CFR 200.303 (Internal Controls) and 2 CFR 200.344 (Closeout). - Implement a standardized checklist for technical analyst and program managers to confirm that all expenditure documentation includes dates verifying that costs were incurred within the period of performance. - Require a secondary review and sign-off by the CIP Administrator prior to submission of documentation to auditors. - Conduct mandatory annual training for program on federal period of performance requirements and required supporting documentation standards. - Provide refresher sessions before each audit cycle. - Establish a quarterly self-audit of grant files to verify that documentation is complete and properly supports expenditures. - Document results of each review and address deficiencies immediately. The responsible official will report progress on corrective actions to the CNMI leadership and maintain documentation of all implemented changes. Evidence of compliance (updated policies, training records, and self-audit reports) will be provided to the auditors upon request. Proposed Completion Date: December 31, 2025

The Government concurs with the auditor's findings and recommendations. As part of the close-out process, all open purchase orders are now submitted to the Department of Finance to be closed. Additionally, the grant close out process has now shifted to OMB to ensure the grant is no longer available for transactions entries or liquidations. Additionally, a dedicated Fiscal Analyst is being inserted into the workflow to ensure compliance.

The Government concurs with the auditor's findings and recommendations. A dedicated Fiscal Analyst has been hired and is now inserted into the approval workflow to ensure compliance. Additionally, any open purchase orders are now closed at the end of the grant year to ensure compliance.

The Government concurs with the auditor's findings and recommendations. The office of Management and Budget will work with the Department of Finance to implement control measures that will prevent the approval of transaction beyond the period of performance.

The Government concurs with the auditor's findings and recommendations. OTAG has updated policies and procedures to address pre-award costs, scope of work, and payout to vendors to abide with the 90 days close out process. OTAG is training new personnel and monitoring implementation.

The Government concurs with the auditor's findings and recommendations. OTAG has improved their internal controls and fully implemented a policy and procedure where the employees have both a manual timesheet and electronic timesheet to verify the time worked. Policies and procedures have been updated to address the validation of payroll process activities. In addition, an Employee Relations Coordinator has been in place to ensure validation input. The Director of Administration and Business Management certifies, and the Agency Head approves of allowable cost/cost principles payroll activities. OTAG is working on the review process relative to the grant and the appropriate period of performance.

The Government concurs with the auditor's findings and recommendations. The Department of Health will make sure that any external consultant confers with their financial division to validate process or actions taken before finalizing any adjustments. In addition, the Department of Health will conduct monthly reconciliation meetings to ensure all adjustments are completed and on time.

2022 – 003: Activities Allowed and Unallowed, Allowable Costs, Period of Performance (Compliance; Internal Controls Over Compliance Material Weakness – 93.U01 Title V Condition: The Organization’s general ledger did not allow for sufficient identification of transactions related to the major program, Title V. Title V expenditures were recorded through journal entries without supporting transaction-level detail. Because of this, the population of expenditures could not be tied to individual transactions, and pulling samples from this population would not provide a reasonable basis for drawing conclusions about the population tested. As a result, we were unable to select transactions for testing or perform the necessary audit procedures to assess compliance with federal requirements. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software used, and Revenue and Disbursements are being classed by Fund. General ledgers are reconciled monthly.

Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: The auditors recommend the Organization design, implement, and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review the current internal controls over allocations and source documentation to identify any gaps or weaknesses and develop a plan to address any identified gaps or weaknesses, including updating policies and procedures as necessary. Management will also communicate the updated policies and procedures to all relevant employees and provide training as needed. Monitoring and testing procedures will be implemented to ensure that the updated policies and procedures are being followed. There will also be regular reviews and updates to the policies and procedures as needed to ensure ongoing effectiveness. Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2025

WHRSD has recently redesigned its Chart of Accounts and deployed a current ERP software program to assist in controls of expenditures of all accounts including grants. WHRSD will be completing a comprehensive review of all Business Office Procedures in the fall of 2025, and plans to update/implement updated standard operating procedures to ensure compliance with Local, State, and Federal laws.

The Organization agrees with the finding and acknowledges the need for strengthened internal controls and documentation related to time and effort reporting, as well as the allocation of expenditures to federally funded grant programs. To address the deficiencies noted, the Organization is developing and implementing formal time and effort reporting procedures to ensure that personnel costs charged to federal grants are supported by actual activity records and certified by employees on a regular basis. This will include the adoption of time distribution systems that comply with 2 CFR Part 200 Subpart E and the requirement for supervisory approval of time reports. Additionally, the Organization will revise its expenditure review and approval processes to require that all costs charged to federal programs are supported by appropriate documentation, including vendor invoices and receipts. Staff involved in grant management and accounting will receive training on federal cost principles, documentation requirements, and period of performance compliance. A document retention policy in accordance with 2 CFR 200.334 will also be established to ensure that all supporting documentation is maintained and readily available for audit and program oversight. Organization Contact Person Responsible for Corrective Action: Joseph Koehler, Director of Finance Anticipated Completion Date: June 30, 2025