Corrective Action Plans

Finding Reference Number: MW2022-008 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: External contract accounting staff in place during audit year 2022 failed to declare program income in advance of the deadline specified by NSF. Program income for 2022 was filed was filed on 3 December 2022, approximately three weeks late. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI continues to use a single payment gateway for events and registration fees which supports segregation of payments per event and per grant. Program income has been reported to NSF accurately and on time as of audit year 2023 and appropriate staff and policies are in place to ensure continued future compliance. Name of Contact Person: • Maureen S. Ako, Director of Finance • Telephone: (339)221-5400 • Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

2022-001 Performance and Financial Reports Submissions Category – Material Weakness in Internal Control and Material Noncompliance Condition: The Authority did not comply with the submission due dates of the Federal Financial Reports established by the OEA in their Notice of Award. In addition, from five reports examined to test compliance with due dates, the submission date could not be verified in four instances, including the Federal Financial Report. Management’s Response: Starting in FY 2024-2025, the Finance Department will maintain detailed records of all payments made, as well as the reimbursement and transfer processes. The LRA’s Finance Department will hire additional personnel to strengthen the internal control of its accounts, disbursements, and fund entries. The new team members will be task with updating and managing accounting records. Together, they have will develop a strict timeline for completing important tasks to ensure a concise and transparent flow of funds. Workloads will be divided, with specific responsibilities assigned to individual team members, including Accounts Receivable, Accounts Payable, Bank Reconciliation, and Bookkeeping. Some responsibilities are interconnected, allowing team members to support each other in case of absence or when assistance is needed. Person in charge: Juan C. Rodriguez Rivera Accounting Official 787-705-7188 Juan.rodriguez@lra.pr.gov Implementation Date: FY 2024-2025

Grant agreements are filed with the respective Budget Officers. The period of performance is entered into the FMIS (Bisan) prior to account setup, which automatically halts transactions after the grant’s closing date.

During the audit period through 2022, there was a transition of fiscal and administrative personnel at the City of Williamsport. Due to findings of an internal financial investigation, the City communicated with appropriate parties and a grand jury was convened. The City has been and continues to be under state and federal criminal investigations since February of 2020. Numerous financial records, extending over a 10-year period, have been provided to investigators. In June of 2022, the City hired a consultant to provide fiscal oversight on an ongoing basis and reconcile, to the extent possible prior financial records. Since that time, the City has enhanced internal control and implemented policies to assure accurate financial reporting and compliance. The City anticipates a similar finding for the December 31, 2020, 2021, and 2022 audits, but with the exception of the results of the criminal investigations, expects to resolve this finding for the December 31, 2023 audit.

The Organization will establish policies and procedures to review grant expenditures for their cutoff and to make sure they are captured within the correct period.

ORCCA's current process at the Energy program level has already improved to ensure proper documentation of eligibility. The Energy program director and staff are currently implementing this internal control at the program level to document the information and proper coding to the correct period. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

ORCCA's current process at the program level has improved to ensure proper documentation of eligibility. The Housing director and staff have implemented this internal control at the program level. The finance department's internal control (as noted earlier) is in place to ensure the payment requests have sufficient supporting documentation. As for record retention, ORCCA hired additional temp workers to ensure completed transactions are filed timely with the goal of going paperless in the near future. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

The Auditors Office will take the lead on tracking and reporting on any future programs such as Coronavirus State and Local Fiscal Recovery Fund.

Recommendation: We recommend that VSS reviews the current financial policies and procedures in order to better serve the organization in documenting compliance with federal cost principals and requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: VSS agrees with CLA in creating internal controls over reviewing year end entries. We have hired an accountant, in addition to our Finance Director and Finance Coordinator to create a system of posting and review. Name(s) of the contact person(s) responsible for corrective action: Jessica Franco, Director of Finance Planned completion date for corrective action plan: 10/1/2022

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Jessica Martinez, Deputy Director Corrective Action Plan: The corrective actions for this finding are identical to those outlined in finding 2022-005. Please refer to the correction action plan for finding 2022-005, which includes specific measures to address this finding. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to the FY21 Corrective Action Plan, CFSC implemented a Subrecipient Monitoring Policy in June 2024 to ensure compliance with the Uniform Guidance for monitoring subrecipients of federal funding, including audit requirements and the verification of suspension and debarment status. To further strengthen compliance and ensure timely verification, CFSC will implement the following actions: 1.Mandatory Pre-Award Verification Timing & Documentation: a.Suspension and debarment status must be verified on SAM.gov by the assigned Grant Specialist before the execution of any subaward agreements. b.The verification data and results will be documented by the assigned Grant Specialist and included in the Risk Assessment process prior to award issuance. c.Any subrecipients flagged as high risk due to past audit findings will undergo enhanced pre-award due diligence before subaward execution to be carried out by the assigned Grant Specialist. 2.Grant Compliance Oversight & Approval: a.The Grants Manager (or designee) will review and approve all subrecipient compliance checks before final award execution. b.Any exceptions or delays in verification must be documented and approved by the CFAO & Deputy Director before proceeding. 3.Quarterly Compliance Audits: a.The Grants Manager (or designee) will conduct quarterly internal audits of subrecipient monitoring files to confirm that suspension & debarment verification was completed timely before subaward execution. b. The Grants Manager will be responsible for reporting any identified deficiencies to senior management and ensuring timely correction for policy reinforcement. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25, with ongoing monitoring and enforcement thereafter.

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

Condition: The Organization made drawdowns after month-end based on budgeted period expenses rather than actual salary expenses to support the amounts being requested for reimbursement. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

2022 – 009: Activities Allowed and Unallowed, Allowable Costs, Period of Availability (Compliance; Internal Controls Over Compliance) (Repeat Finding: 2018-006, 2019-008, 2020-008 and 2021-007) Significant Deficiency ALN 93.441 Indian Self Determination ALN 20.205 Highway Planning & Construction ALN 15.030 Indian Law Enforcement ALN 93.575 Child Care and Development Block Grant ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds (ARPA) Condition: During compliance requirement testing for Activities Allowed and Unallowed, Allowable Costs and Period of Performance for the above noted major programs, we selected 120 transactions for testing from each major program. The following number of transactions were not provided for our review during the audit: ALN 93.441 – Indian Self Determination – 47 transactions ALN 20.205 – Highway Planning and Construction - 11 transactions ALN 15.030 – Indian Law Enforcement – 8 transactions ALN 93.575 – Child Care and Development Block Grant – 22 transactions ALN 21.027 – Coronavirus State and Local Fiscal Recovery Funds – 9 transactions Corrective Action Plan: The Finance Department will become familiar with the requirements of 2 CFR, Part §200.313(a) and establish appropriate internal control policies and procedures to ensure compliance with the requirements of Uniform Guidance and each major program. In addition, all staff will be trained on those policies and procedures so they are familiar with the requirements. The Finance Department will not process payment for disbursements that does not contain sufficient, appropriate supporting documentation and necessary approvals. The Finance Department will implement and execute an internal audit, by pulling random vouchers packets to test for compliance mid-year.

FA 2022-004 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: SO10A200010 (Year: 2021) SO10A210010-21A (Year: 2022) Questioned Costs: $37,644 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: Terrance H. Freeman, III CFO Telephone: 706-665-8577 Email: tfreeman@talbot.k12.ga.us

Finding 2022-005: Lack of Internal Control And Noncompliance With Activities Allowed or Unallowed; Allowable Costs/Cost Principles; and Period of Performance Name of Contact: Josh Verhagen Corrective Action Plan: New and improved weekly communication between grant team and finance team. Proposed Completion Date: March 2025

Management agrees with the findings and has already initiated corrective actions. Moving forward, budget-to-actual comparisons will be prepared monthly, and any discrepancies will be addressed promptly. The organization will work closely with the cognizant agency to arrange for the return of any unobligated funds or, if applicable, seek authorization to retain the funds for use in other similar programs. This process will ensure proper financial management and compliance.

FINDING 2022-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness, Modified Opinion The County did not have an effective internal control system to ensure compliance with the Reporting compliance requirement. Recipients are required to submit quarterly or annually Project and Expenditure (P&E) Reports to the Department of the Treasury (Treasury). The County submitted four quarterly P&E Reports during the audit period. The County's process for the completion and submission of the P&E Reports was that the County Auditor prepared each P&E Report based on the County's Financial Ledgers, without a proper oversight or review process in place prior to submission. All four quarterly reports that were due during the audit period were not properly supported by the County's records Contact Person Responsible for Corrective Action: Timothy Stabosz Contact Phone Number and Email Address: 219-326-6808 x2226 tstabosz@laporteco.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct this finding, we will require one person to complete the report and another to review the report prior to submission. Anticipated Completion Date: We will begin requirement a review prior to submission as of November 21, 2024.

2022-002 Material Weakness in internal controls over compliance with period of performance. Name of Contact Person: Chris Conley, Chief Accountant. Corrective action: To ensure this does not occur again, the City Accountant and Chief Accountant will review all journal entries to make sure that expenses are charges with the appropriate project period and with the definitions of the grant. We will train and have training documents for the City Accountant when the come into this position. Proposed Completion Date: Immediately. Implementation date: Immediately.

Finding Reference Number: 2022-002 Federal Agency: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus Relief Fund ALN Number: 21.019 Responsible Official: County Commission Views of Responsible Individuals: We understand the importance of having adequate documentation for Federal Grant programs. We hired an outside agency to oversee the Coronavirus Relief Fund who did not provide us the adequate documentation needed. We did; however, provide email confirmations that the monies spent were reported to the Treasury. The County will handle all Federal Grant programs in the future to ensure that adequate documentation is maintained by the County.

FINDING 2022-005 Finding Subject: CDBG ‐ Entitlement Grants Cluster ‐ Period of Performance Summary of Finding: The county did not have properly designed internal controls in order to prevent or detect errors in the general ledger for activities related to adjustments to Community Development Block Grant funds during the transition and implementation of the Oracle accounting system. Contact Person Responsible for Corrective Action: Dan Ciecierski, Comptroller Contact Phone Number and Email Address: 219-755-3137 | ciecidx@lakecountyin.org Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: Lake County has begun execution of a comprehensive strategy in order to address the lack of internal controls around its financial transactions and reporting in a number of ways. The following will address control issues identified in these areas: - Financial Transactions and Reporting - Employee Benefit Accrual (EBA) Fund - Cash and Investments - Receipts - Journal Entries - Financial Statement & Reporting First, a more qualified consulting firm has been hired to assist on two important fronts related to the new accounting system: 1. The first is the reimplementation of the Oracle accounting software which is inclusive of correcting data and poor configurations from the prior consultant, and deploying additional appropriate functionality to allow the County to optimize Oracle to suit the accounting needs from a process standpoint as well as an internal control perspective. Oracle in and of itself allows the county to implement strategic preventative internal controls via role-based access features. Said differently, Oracle has a more robust and granular ability to automatically create separation of INDIANA STATE BOARD OF ACCOUNTS 41 duties among employees and departments simply by restricting the ability to perform actions which should be naturally segregated to mitigate risk of error. 2. Secondly, the managed services portion of the consulting contract will aid the County in running the business activities related to both the Oracle Human Capital Management (HCM) module and the Enterprise Resource Planning (ERP) module (Purchasing, Accounts Receivable, Accounts Payable, and General Accounting). Another initiative being executed to address the lack of internal controls is to attract, and hire qualified professionals who have years of real world, practical experience in the field for which a job relates to. During the original implementation of the Oracle system there was no one who fully understood, nor had a background in the professional field of accounting in the Auditor’s Office. The County has hired a Comptroller who passed the CPA, and has spent their entire career in the field of accounting. This individual has worked in the corporate utility and banking industries and has experience in GAAP reporting, regulatory reporting, internal controls, and overall general accounting. Additionally, the Comptroller has been involved with internal and external audit compliance as well as the installation, user acceptance testing, and transition of new accounting software. In order to mitigate the risk of error for any adjusting entries made which are recommended by consultants, the Comptroller of Finance must review and approve these entries. Anticipated Completion Date: 1. This process has already been put into place and is being executed.

As of October 2022, EPEC updated our grant expense approval process. As with all purchases and payroll, grant expenditures will be approved by a Director (Director team consists of: Executive Director, Director of Finance, Director of Outreach, and Director of Shelter), and when paid, will be assessed for accuracy again by EPEC’s contracted CPA. Approvals will be documented on each paper bill or electronically via email or DocuSign, when appropriate.

Finding 2022-016 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Management’s Response: Management agrees it is critical to ensure spending occurs within the applicable expenditure periods. In the new financial management system (Workday), we have established parameters to fence the applicable expenditure periods. Further we are making gains to close out awards to further disallow spend outside the applicable expenditure periods. There was departmental turnover within the department at the end of 2022 with a loss of knowledge transfer during the change in personnel. Views of Responsible Officials and Corrective Action: With the aid of technology available through our new ERP system, management plans to enhance operations by having training documents and processes for various awards so as personnel attrition occurs there is continuity in processes. 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

Finding 2022-015 U.S Department of Housing and Urban Development Emergency Solutions Grant Program - 14.231, Award number E-22-MC-20-0001 Management’s Response: Management agrees that the matching component should be tracked to ensure compliance with the terms of the award. Views of Responsible Officials and Corrective Action: With our new ERP system, in the grant/award module, the Unified Government of Wyandotte County & Kansas City KS are working with departments to establish match components and trackable spend items to enhance compliance with award terms. 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