Corrective Action Plans

Finding 2022-013 U.S Department of Homeland Security Staffing for Adequate Fire and Emergency Response (SAFER) – 97.083, Award Number EMW-2019-FF-0819 Management’s Response: Management agrees spend controls are an important part of grant compliance. Management continues to improve compliance and controls over awards to ensure compliance. In 2023 we converted to a new ERP system and part of the conversion was implementing spend controls to aid in compliance for awards to minimize future issues. Views of Responsible Officials and Corrective Action: Management will work with stakeholders so that only the allowed costs are used as the basis of the reimbursement packet. We have also created fencing around allowed costs and period of performance in our new ERP system. 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

Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Southwestern Christian University will designate multiple staff to oversee the guidelines and disbursements of all federal money. The Interim CFO is responsible for the reconciliation of expenditures and drawdowns from any future federal funds. Person Responsible for Corrective Action Plan: Bill Martin, Interim CFO Anticipated Date of Completion: Immediately

Finding No. 2022-005 KCHC disagrees with the finding that it is in noncompliance with the applicable period of performance requirements. The sample request was received after the August 19 meeting with the CEO and board representative, during which it was noted that no further samples would be accepted as the audit had extended beyond one year. The delays were due to staffing challenges both on the part of the auditor and within KCHC. In FY 2025, KCHC has started the following corrective actions ensuring that all records are systematically filed and digitized for easy retrieval, regardless of changes in staff. This new system allows for seamless access to documents and a clear audit trail: 1. DocuSign for Document Management: In FY2025, KCHC adopted DocuSign to facilitate the management of financial documents. While DocuSign does not automatically upload supporting documents to the accounting software, it provides an efficient way to manage approvals and ensure an audit trail. After approval, the assigned accountant is responsible for manually uploading the supporting documents into the accounting software to ensure they are properly recorded and retrievable for audit purposes. 2. Timely Upload and Filing of Documentation: To address the delays, KCHC has updated its procedures requiring that all financial staff upload supporting documents at the time of expenditure approval or payment. This process will ensure that no documentation is missing or delayed, and all records are maintained in compliance with federal guidelines. 3. Ongoing Monitoring and Reporting: The CFO will oversee quarterly internal audits to ensure that the enhanced recordkeeping system is functioning effectively and that all expenditures continue to comply with the period of performance requirements. Progress will be reported to the Board of Directors to ensure transparency and ongoing compliance. By taking these corrective actions, KCHC will ensure that all expenditures are supported by proper documentation, uploaded timely, and readily available for audit review, preventing any future delays or compliance issues. Implementation Timeline: Completed as of August 31, 2024 with continued updates and monitoring. Responsible person: Arlene Deleon Guerrero, CFO

Finding 2022-003: Reconciliation of Accounts Federal Program: Research and Development Cluster (Education and Human Resources)Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1500529 (9/1/2015 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022) Condition: The year-end schedules for federal grants receivable, net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 10/15/2024 Responsible Official: Michael Brosnan, CFO

Federal Award Findings and Questioned Costs: Finding 2022-003: Reporting - Timely Submission of Financial Reports – Significant Deficiency in Internal Control over Compliance and Noncompliance Name of Contact Person: Stephen Wilson, Finance Director Corrective Action Plan: As the Borough is currently behind on its audit’s we are aware that this will continue to be an issue until we are caught up. Completion Date: June 30, 2025

All invoices and documentation related to expenditure of federal funds are now scanned and attached to the accounting entry recording the payable. With regards to the Client Acknowledgement of Receipt of Direct Assistance Forms, we have taken steps to ensure that the documentation is signed at the time assistance is given and continue to work with the refugees as to the importance of having the proper paperwork on file.

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to specify documentation and maintenance of such documentation of the review and approval of costs allocated to federal grants within the grant funding period. 2) Update grant policies to include subrecipient periodic submission of supporting documentation. Completion Date: July 10, 2024 Explanation: Management concurs that the procedures should specify documentation and maintenance of such documentation of the review and approval of costs allocated/charged to the federal grant within the grant funding period. Grant policies and procedures have been updated to include subrecipient periodic submission of general ledger or other financial documentation supporting expenditures during the period.

Finding 2022-004 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: The Period of Availability for the SPED PL 94-142 Grant was September 29, 2021 through September 30, 2023. Condition: During our test of controls over compliance it was noted that there are expenditures charged to the SPED PL 94-142 Grant (September 29, 2021 through September 30, 2023) for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Context: During our test of expenditures and review of the general ledger against the SPED PL 94-142 Grant as it is related to compliance it was noted that the first payroll charged to the grant were for services prior to the grant start date of September 29, 2021 and thus would be outside the period of performance and thus would not be allowable costs. Effect: The School Department was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned costs for the first payroll charged to the grant whose service period was prior to the grant start date of September 29, 2021 was $7,249.98. Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing. Recommendation: We recommend the School Department follow procedures to ensure that expenditures charged to the grant are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Managements Response: Management agrees with the auditors’ findings and will put in procedures and policies to correct the action going forward. Responsible for Corrective Plan: Patrick McIntyre, School Business Manager Estimated Completion Date: Fiscal Year 2023 Action Taken: The School Department ensures that expenditures charged to the grant only once approved and within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education (DESE). Accounting codes are not set up for individual grants until final approval from DESE.

Invoices that are received will be scanned to “invoices”. This will direct them to our electronic software, Docuware. The item will then be forwarded to the appropriate Program Director for approval, and they will indicate the appropriate cost centers / allocations. Bookers will then review the approved coding and entered fiscal software. If there is a question or concern about approved coding by the bookkeeper they will speak with Director of Finance, Ethan Terrio. Once invoices are entered into fiscal software, checks will be printed. The check stub and invoice will be attached to each other and filed in the fiscal department. Paper documents will continue to be maintained in fiscal until we go 100% paperless, then all documents will be stored in Docuware.

1. Processes related to the program stating roles of each individual involved in the process were documented and implemented in September 2022. 2. Regular risk assessment and monitoring functions are performed by management and grant awarders.

Following the completion of the 2021 Single Audit, we adjusted the Organization's Accounting Policies & Procedure Manual to include detailed information outlined in HUD's electronic Line of Credit Control System (eLOCCS) inclusive of the roles and responsibilities of the system's Users and Approving Official. Specifically, Accounting Department Leadership (i.e., the Chief Financial Officer), designated accounting personnel (i.e., Accountants), and/or agency Executive Leadership (i.e., CEO/Executive Director), must be cognizant of a grant's period of performance.

97.036 - Noncompliance with Period of Performance Requirement – Disaster Grants - Public Assistance (Presidentially Declared Disasters) Oklahoma County will design and implement internal control procedures to ensure that all period of performance requirements are met. Anticipated Completion Date: Completed and approved at BOCC on 3/27/2024 Responsible Contact Person: Brian Maughan, BOCC Chairman

January 12, 2023To Whom It May Concern:Finding 2022-001Finding 2022-001 addresses the use of CRF funding and the purchase made that covered period 8/25/21-8/24/22. The District moved forward with this expenditure in good faith based on their understanding of expenditure allowances and reporting. However, because the contract was for yearlong services and extended beyond the close of the reporting window on 10/06/21, CRF funding should not have been utilized.The District has contacted and shared the finding with CDE for additional guidance of how they want us to correct this matter. The District will also implement moving forward a check and balance system of working with the grantee to clarify any concerns about deadlines or allowable expenditures. If further assistance is needed we will work with our auditors to make the adjustments needed.Respectfully,Jorge MartinezDirector, Fiscal ServicesBellflower Unified School District562-866-9011 x 2161

FINDING # 2022-024No finding in prior yearThe New Jersey Department of Labor and Workforce Development (DLWD) has a policy in place for processing tuition reimbursements that are performed by the Department?s Accounts Payable unit. The policy was reviewed by the Office of Finance & Accounting (F&A) and internal control procedures were enhanced to ensure that fiscal cutoff measures were appropriately addressed. Tuition reimbursement procedures include having the requests forwarded to the responsible Supervising Analyst in the Appropriations/Accounting unit for final review and approval to ensure the proper fiscal period is charged. The correcting transactions were completed during the Single Audit timeframe to remediate the findings by charging and reimbursing the proper fiscal year accounts. The DLWD will continue its efforts to ensure compliance and that all charges applied to Federal awards are within the specified period of performance going forward.COMPLETION DATE/CONTACT PERSON December 31, 2023Ruslana Nagorniak(609) 984-7678Ruslana.Nagorniak@dol.nj.gov

FINDING # 2022-021No finding in prior yearThe Department of Children and Families (DCF) will review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within each grant award?s specified period of performance.Further, as the federal SSBG grant award cited has a period of performance that remains open through September 2023, DCF has adjusted the four transactions that were posted incorrectly to another available funding source and ensured that all transactions presently recorded are now in compliance and within the specified period of performance.COMPLETION DATE/CONTACT PERSON Fiscal Year 2024Steven M. Dodson(609) 888-7555Steven.Dodson@dcf.nj.gov

September 14, 2023This is a corrective action plan in response to the audit finding on our FY2022 Single Audit (2022-001) provided to the Town of Rutland on 8/29/2023.Planned Corrective ActionDuring FY2022 and FY2023 there were significant changes to staffing in the Town Administrator and Town Accountants offices. The project to create formalized written policies and procedures that are required under the Uniform Guidance was not completed. The Town has draft policy and procedures established that will be adopted by the Board of Selectmen and will be implemented for fiscal year 2024.Contact person and Completion dateThe Town Administrators office will be facilitating the implementation of the new policy and procedures that will bring us into compliance with the Uniform Guidance for FY2024. The contact information for his office is as follows:Austin Cyganiewicz, Town Admin. ? acyganiewicz@townofrutland.org 508-886-4100 ext. 1000Tomeca Murphy, Executive Asst to TA & BOS ? tmurphy@townofrutland.org 508-886-4100 ext. 2001

Finding 2022-005 ReportingThe Corporation management agreed with the finding. As of August 15, 2023, the Corporation will remove any individual submissions from the general submission and reconcile the general submission to the supporting documentation less these individual submissions. The Corporation does not expect to receive any further funding from the ARP or PRF and has no further reporting requirements under this grant.Responsible Personnel include Harley McCoige, Controller, Cortney Couture, Director of Accounting, and Samantha Pratt, Director of Internal audit.

Finding 2022-004 Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Special Test and ProvisionsThe Corporation management agreed with the finding. Effective September 1, 2022, The Corporation has implemented the following changes, which we believe would address future internal control considerations.The below procedures were added to the grant checklist which is required on all grants applied for by the Corporation entities. Responsible parties are required to document all procedures and sign off on these procedures. The requirements formalize reporting and data management procedures, which include proper management approval and retention of these records. The grant checklist is additionally approved by the grant applicant and Vice President or Executive Director overseeing the grant.Determine required data requests in order to support this grant:? All data requests should list required data fields and constraints and must be reviewed and approved by management.? Detail sample review of the results must be performed to validate the accuracy and completeness of data and that report results meet the grant requirements.? Report access should be restricted to approved users or report results must be validated to approved constraints.Documentation of these procedures must be retained with management sign off and readily available upon request.Grants in excess of $187,500 require review by Finance or Internal Audit representative to verify that appropriate procedures are in place for documentation of controls on reporting and data management.Responsible Personnel beyond the specific Vice President or Executive director of the grant include Harley McCoige, Controller, Cortney Couture, Director of Accounting, and Samantha Pratt, Director of Internal audit.

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are applied to the correct period for the correct amount after the Accounting Coordinator inputs the data to ensure that Federal funds are reimbursed accurately and in the appropriate period

Vendor invoice processing is performed by the Accounting Coordinator who inputs pertinent invoice data into the accounting software for payment. The UWGC Senior Director of Finance or in her absence the UWGC Chief Financial Officer will provide a secondary level of review to verify invoices are applied to the correct period for the correct amount after the Accounting Coordinator inputs the data to ensure that Federal funds are reimbursed accurately and in the appropriate period.

Management will ensure that accrued expenses are reviewed in detail at grant year end to ensure only costs incurred prior to year end are accrued and reported as grant expenditures.

Finding: 2022-048 - Auditors could not obtain sufficient and appropriate evidence to verify compliance with LIHEAP? s period of performance requirements.Questioned Costs: NoneAssistance Listing Number: 93.568Assistance Listing Title: LIHEAPViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): DOH agrees with the finding.Corrective Action (corrective action planned): The Division of Public Assistance plans to review all current LIHEAP compliance procedures to identify areas for improvement. Potential modification of accounting structures will be examined as well. Staff training will take place to ensure any new procedures are fully understood prior to official implementation of updated processes.Completion Date (list anticipated completion date): DOH anticipates the finding will be resolved in FY2024.Agency Contact (name of person responsible for corrective action): Josephine Stern, Assistant Commissioner

Finding: 2022-070 - Testing of five subawards subject to Federal Funding Accountability and Transparency Act (FFATA) requirements had obligated amounts incorrectly reported to the FFATA Subaward Reporting System, or not reported at all.Questioned Costs: NoneAssistance Listing Number: 66.202Assistance Listing Title: Congressionally Mandated ProjectsViews of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): AgreeCorrective Action (corrective action planned): FFATA Quality Compliance Plan:1. Develop and immediately implement Standard Operating Procedures to be incorporated into the staff instruction manual for FFATA reporting protocols.2. Develop, implement, and maintain a spreadsheet of all FFATA ? mandated subaward reporting, containing a comprehensive list, by federal grant funding source, including due dates and sign-off by responsible staff member when submitted into the FSRS system.3. Train all relevant staff on the procedure manual and FFATA Report Tracking spreadsheet.Completion Date (list anticipated completion date): May 30, 2023Agency Contact (name of person responsible for corrective action): Jenn Brown

Finding 2022-006Significant deficiency in compliance and internal controls over compliance and instance of noncompliance related to periodof performance.Contact Person(s):Nicholas Lee, Chief Financial OfficerCorrective action planned:Vacated billing staff position filled and additional support staff retraining underway to ensure incurred costs documentationis available for processing during the period of performance and subsequent cost reimbursements bills are submitted tofederal awards within appropriate period of performance timeframe.Anticipated completion date:June 30, 2023

FINDING 2022-002Contact Person Responsible for Corrective Action: Janetta C HardyContact Phone Number: 812-752-4343 X222Views of Responsible Official:I concur with the finding.Description of Corrective Action Plan:In April of 2022 the City of Scottsburg?s annual reporting of COVID 19 ? State and Local Fiscal RecoveryFunds for 2021 provided the Common Council?s allocated expenditures for the reporting period instead ofactual expenditures for the reporting period. This error was corrected in the 2023 reporting for April 1,2022 ? Mar 31, 2023 expenditures. However the cumulative obligations and the current periodobligations were again reported as the total grant award. This will be corrected in the April 2024reporting.In regards to this finding, as clerk treasurer I reviewed the report created by Tish Richey and submittedwith inaccurate numbers. I qualify this under human error, commonly known as a mistake. In the future, Iwill do my best to not make a mistake in reporting and retain the initialed documentation for what issubmitted. Lastly, this was the first year for federal reporting of these funds and the instructions wereambiguous at best.Anticipated Completion Date: April 2024