Corrective Action Plans

To be determined

2022-060 Higher Education Coordinating Commission Strenthen controls to ensure expenditures are not obligated beyond the period of performance Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Years: AA32218F30; 2018, AA32218G10; 2018 AA32218G30; 2018, AA32218G70; 2018 AA32218H90; 2018, AA32218F31; 2018 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $47,523 (known) Criteria: 20 CFR 683.110; 2 CFR 200.343 (2018) WIOA grants are available for expenditure by the State during the grant program year and the two succeeding program years. In addition, the State must liquidate all financial obligations incurred no later than 90 calendar days after the end date of the period of performance. We judgmentally selected for review expenditures recorded in fiscal year 2022 related to 2018 grant award whose period of performance ended June 30, 2021. Our review of the supporting documentation found there were 3 out of 13 items with expenditures that were outside the period of performance. Total question cost for these expenditures were $47,523. Per management, these errors were due to a change in personnel and trying to balance out the 2018 grant after the fact. We recommend department management review and revise controls to ensure expenditures are only obligated during the period of performance federally mandated dates. MANAGEMENT RESPONSE: We agree with this recommendation. The three errors pertaining to those expenditures that were outside the period of performance, were due to a change in personnel and trying to balance out the 2018 grant, after the fact. The HECC have addressed these issues by ensuring that all new accountants are fully trained in a timely manner. Also, HECC has implemented training for all current accounting staff in identifying what is an allowable cost within the period of performance. This training also included a review of proper close-out procedures for all grants. Anticipated Completion Date: June 30, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

Finding 2022-008 Federal Listing Number 16.560 ? Allowable Costs; Period of Performance Corrective Action Plan Management will recognize revenue for cost reimbursable grants and contracts as the expenses are incurred. The sub-recipients will be paid as the expenses are incurred/invoiced. In 2023, WizeHive, a project management application, has been implemented to track grant and contract spending and invoicing. Accounting and Operations. Management will document the internal control procedures used to manage federal awards to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. The internal control procedures will include the monitoring of Subrecipients. Anticipated Completion Date November 30, 2023 Name of Contact Person Responsible for Corrective Action Angelo DeSantis, YPTC

Management agrees with the comment. The Finance Department in coordination with Planning and Development will create and implement internal procedures for reviewing contracts and award agreements to ensure the applicable deadlines are being followed.

Finding 2022-001 - Allowable Costs/Activities, Period of Availability and Reporting; Material Weakness Responsible Person: Toneq? McCullough, Director of Transportation Action: During fiscal year 2022, the City?s Department of Transportation recognized a need for additional controls in reviewing and approving contractor invoices prior to submission to the Finance Department for payment. While additional controls were implemented during the year for non-payroll expenditures, developing a similar procedure for payroll invoices was inadvertently overlooked. As of September 2022, the City updated the process by which payroll invoices are approved and paid and the invoices are now approved by the Director of Transportation. The City?s Department of Transportation will begin reviewing and approving the non-financial information in the Annual Operating Statistics Report as of November 2022. Anticipated Completion Date: November 2022

View of Responsible Official(s) and Planned Corrective Action: The Commission agrees that the finding identified by UHY occurred. Specifically, the Commission requested reimbursement of $33,494 of expenses prior to the period of performance start date of the award. The Commission has since remedied this finding by paying back the federal awarding agency in February 2023 for the amount and utilizing another federal grant to charge the expenses to. In the future, the review of grant reimbursement requests will explicitly include consideration that the expenses charged to an award are within the period of performance by documenting said period on the requests approval form.

FINDING 2022-006 Contact Person Responsible for Corrective Action: Commissioners: Thomas Helmer, David Berry and Ricky Woodall Contact Phone Number: T. Helmer 765-795-4035, D. Berry 765-522-1775, R. Woodall 765-653-3757 Views of Responsible Officials: Concur with audit finding. Description of Corrective Action Plan: this was the first (for current officers) time getting this large of funds and jumping through all the necessary hoops and the county did not have anything in place prior to go off on how to proceed from start to finish. The county hired Barnes & Thornburg with the impression they would be walking us through the entire process and helping with all the reports. Commissioner Woodall had volunteered to be the county?s designee on handling all the reports necessary to do with the ARPA funds. He did them with the help he would receive from telephone calls with Barnes & Thornburg and the State. The county is going to hire someone (or an accounting firm) to start doing the reports and to make sure the county is complying with what needs to be done. Then, two county employees will have a review process to make sure the proper steps are being followed and the figures being turned in match what the county is showing has been receipted in and disbursed for each quarter and annually. Anticipated Completion Date: March 1, 2024

FINDING 2022-004 Contact Person Responsible for Corrective Action: Auditor Kristina Berish Contact Phone Number: 765-653-5513 Views of Responsible Officials: Concur with audit finding. Description of Corrective Action Plan: Payroll vouchers, there were 8 vouchers of 26 tested that did not have the department head signatures on them. It was the premium pay vouchers. The payroll deputy had been instructed after the 2021 audit to make sure all timesheets and payroll vouchers were signed. Corrective action is that this deputy is no longer employed. We now have a Payroll Deputy and a Human Resources Deputy who after each payroll look at all the timesheets and payroll vouchers to make sure they are signed. They both must sign off on it verifying they were reviewed for compliance. The following was an internal control issue pertaining to the period of performance requirement. The premium pay was not set up as a separate pay record for all the employees eligible to receive it. It was done as an adjustment to add the pay along with their regular paycheck. Felt it was an unnecessary amount of time to set up a separate pay record for one check. However, in doing it this way there was not a way to separate the matching taxes and PERF for the premium pay so there was an adjustment made after the payroll so it would be paid from the ARPA funds. There is a report that was ran and printed. It was shown to the audit team showing how the adjustments amount were generated in the payroll program. Chief Deputy Auditor went into our financial program to make the adjustments. We were unaware that since this is Federal monies, we needed to have something besides a verbal discussion on how to make the adjustments and the corresponding report. Corrective Action is in the future if any such adjustments need to be made there will be a verbal understanding of what needs to be done, reports, and something in writing between two employees in the Auditor?s Office stating who, what and why adjustments are being made. And someone signed off that they reviewed the adjustments after they were made. Anticipated Completion Date: March 1, 2024

2022-002 Community Services Block Grant? CFDA No. 93.569 Noncompliance: Out of the forty expenditures tested, one expenditure included FY2022 and FY2023 amounts. The expenditure included amounts related to October 2022, which is after the federal award period of performance, but was expensed in full to the award as of September 30, 2022. Recommendation: We recommend that Management strengthen their processes, controls, and review over direct federal award expenditures and ensure compliance with Uniform Administrative Requirements. In addition, management should seek appropriate training for financial department staff to ensure proper cutoff of program expenditures. Responsible Person for Corrective Action: Megan Hannan, Executive Director Corrective Action to be Taken: Management and the fiscal agent will review end of year invoices for dates of service as they are processed for necessary accruals between fiscal years to validate charges to appropriate federal awards. Financial training will be provided as needed and requested to avoid future findings. The anticipated completion date for this corrective action is 9.30.23

Finding 2022-002: Considered a significant deficiency in internal control over compliance/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (ARPA Prevention) Criteria: As detailed by 2 CFR 200.309, ?A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity.?. Condition: During testing it was noted that $112,581 of costs that were allowable under ARPA Treatment were incorrectly allocated from ARPA Treatment to ARPA Prevention. Corrective Action: All finance staff responsible for any allocation of grant funding have undergone additional training or reading on how to allocate grants. The was completed by April 30, 2023.

2022-003 Review and Approval of Grant Expenditures (Significant Deficiency) Department of Health and Human Services Unaccompanied Alien Children Program, Assistance Listing Number 93.676 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles and Period of Performance Recommendation: The Organization should implement controls and processes that ensure grant expenditures charged to the program are reviewed to ensure costs are allowable and properly supported. Action Taken (Unaudited):. All expenses must be approved by the Executive Director prior to payment. Approvals are documented either via physical signature or email. A schedule has been established so that expenses are reviewed in a more timely and organized manner. Contact Name ? Kaleena Harmer Expected Completion Date ? 08/31/2022

Views of Responsible Officials and Planned Corrective Action: The Home disagrees with the disallowance and maintains that the ACF made legal and factual errors in taking the disallowance and that expenses incurred were necessary, reasonable, allocable and allowable. The Home is working with a consultant to establish standard operating procedures and workflows relating to the accounting function.

Finding 2022-001 Corrective Action Plan: Arden Theatre Company will review supporting documentation for costs applied to grant awards to ensure they are recorded in the proper periods in the accounting software and grant award submissions. In regards to this finding, Arden Theatre Company reviewed costs applied to the SVOG grant to ensure only those that were incurred during the SVOG period of March 1, 2020 to June 30, 2022 were included. Any identified costs that occurred outside of the period were replaced with allowable costs that were incurred during the SVOG period. Anticipated Completion Date: Arden Theatre Company has implemented this corrective action as of December 13, 2022. Name of Contact Person Responsible for Corrective Action: Amy Murphy, Managing Director

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and maintain effective internal controls over the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Lori Dawn Dickinson will review the P&E Report to verify that all entries are accurate and true, and I (Heather Perry) will submit the report. Heather Perry Greene County Auditor Anticipated Completion Date: April 30, 2024

Finding 2022-001: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late FY22 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: ? Revised the current timekeeping policy to clarify employee and manager responsibilities ? Modified failure to comply provisions ? Deployed educational programs for both management and staff ? Reviewed/improved Kronos Time and Attendance system automated notifications ? Made training resources available to management and staff via our Scripps intranet site Leadership monitors policy compliance by individual employee and manager via systemwide reporting on a biweekly basis. Contact person: Eric Cole Expected Completion Date: Completed ? September 2022

CORRECTIVE ACTION PLAN June 22, 2023 Department of the Treasury - CDFI Fund Grant River City Federal Credit Union respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Doeren Mayhew 305 West Big Beaver Rd., Ste. 200 Troy, MI 48084 Audit period: January 1, 2022- December 31, 2022 The findings from the December 31, 2022, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF TREASURY CDFI Program - CFDA No. 21.024 Significant Deficiency: See Finding 2022-001. Recommendation: Complete established procedures to identify and track eligible loans deployed during the RRP grant performance period and reconcile the totals to the underlying loan data. Action Taken: Management already has an established process to internally track eligible loans deployed during the RRP grant performance, some of the data compilation is automated and some require manual updating. Management has already replaced manual processes with excel functions like vlookup to reduce errors identified by Doeren. However, management has used this conservative process year after year and is confident with the method based on third party verification from Inclusiv, who reports annual data to the CDFI Fund, and acceptance by the CDFI Fund on an annual basis and by an additional independent 3rd party who reports annual grant requirements to the CDFI fund. Management is also confident that this current process appropriately tracks deployed loans required under the RRP Grant performance based on the sheer volume of loans granted annually. With under $2M in loans needed to satisfy the grant requirement in 2022, the credit union has identified a minimum of $20 million in eligible loans in eligible markets, well above the grant performance requirements. The current process would require a significant error rate of over 80% to fail in meeting grant performance requirement. Management does not agree with Doeren auditors' assessment of noncompliance based on the auditors performing a lin1ited scope, only reviewing 40 of the 3,676 loans funded in 2022. The 1.1% of loan evaluated is in1material and gives a false impression of the true effectiveness of the overall internal control process. With 2 errors identified in the sample of 40, Doreen auditors use this as a basis to recognize a significant deficiency- an evaluation management does not concur with. Doreen's evaluation was based on guidance for control-based auditing that is standard in the industry. Doreen's evaluation was also based on an assessment of the credit union's specific target markets, not in accordance with the grant agreement, which allows financial products in any eligible CDFI market and/or the credit union's approved target market. This generic industry standard assessment fails to consider household size in income evaluations and fails to consider underserved racial groups prevalent in Bexar County and identified as eligible CDFI targeted populations. Management is confident in its internal controls and welcomes the Department of Treasury to review its 2022 loan data and internal process by doing an in-depth analysis on a significant percentage of its total loans to verify internal controls are valid and acceptable to meet the grant performance in any eligible CDFI markets and the credit union's approved target market. If the Department of Treasury has questions regarding this plan, please call Michael Quintanilla, Chief Financial Officer at (210) 225-6866.

Suggested Action (s)- Create an SR (Service Request) with Oracle to prevent transactions coming from subledgers after the award expiration date. Update and share the award closeout checklist under the ERP platform emphasizing the critical activities and timelines to ensure successful and timely closure of awards. Develop additional reports in ERP system to support the analysis of expenses charged to the awards after their expiration dates for timely remedial actions. Responsible Official- Global Controller Senior Director Finance Systems & Operations Regional Finance Officers Country Program SMT. Completion Date- September 30th, 2023.

Finding 2022-008 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University will document lost revenue in comparison to the Board of Regents approved budget. The calculation will be prepared by the Assistant Comptroller, reviewed by the Comptroller as the 2nd reviewer, and approved by the Chief Financial Officer, as the 3rd and final review for charges being allocated to the grant.

Finding 2022-007 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: June 2023 Corrective Action Plan: The University's current process is to collect and retain procurement documents for no less than five years. The institution will work to strengthen the current process in place relevant to securing adequate documentation. Supporting documentation was provided for data selection relating to the upgrades to the HVAC, ventilation, and the spacing of the academic facilities which were all completed in accordance with Covid guidelines. The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

Corrective Action Plan Finding: 2022-002-Capital Fund Deadlines Not Met-Period of Performance and Reporting Condition: (a)-HUD notified the Authority be letter that an insufficient amount of the CFP 2018 program was drawn down by the obligation deadline of May 28, 2022. We noted previously that the current E.D. did not start until May 25, 2022. (b)-As of the year end of this audit, September 30, 2022, the 2016 CFP program had been closed at least for four years. The AMCC and final costs breakdown have not been issued. Corrective Action Planned We will comply with the auditor?s recommendation. Person responsible for corrective action: Sharon Dixson, Executive Director Telephone: (318) 247-6035 Housing Authority of Grambling, Louisiana Fax: (318) 247-6554 300 B.T. Woodard Circle Grambling, LA 71245 Anticipated Completion Date- May 28, 2023

CORRECTIVE ACTION PLAN The Maxwell C. King Center for the Performing Arts, Inc. respectively submits the following corrective action plan for the year ended June 30, 2022. Carr, Riggs & Ingram, LLC 215 Baytree Drive Melbourne, Florida 32940 Audit Period: Fiscal Year July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs dated November 1, 2022 are discussed below. The findings are numbered consistently with the number assigned in the schedule. MW 2021-001 REVIEW & SEGREATION OF DUTIES Recommendation: We recommend the Center implement procedures to ensure all journal entries, bank reconciliations, payroll registers, settlement statements, and customer invoices are reviewed by someone independent from the preparer, and there is sufficient evidence retained to determine the review occurred. The Center should also implement procedures to ensure purchase orders are reviewed to verify the expenditure is allowable and within budget or funding source restrictions. Additionally, we recommend the Center implement procedures to ensure that billing and the posting of cash receipts are independent of cash handling and the preparation of deposits. Corrective Action: Management concurs with the suggestion. The operations management company has since filled the vacant position that will enhance review procedures and segregation of duties. ASM has committed to the board that they will provide a backup, from another ASM office, in the event of a subsequent position vacancy. This support will continue until the position is filled to ensure no lapse in internal controls will occur as a result of the vacancy. Responsible Party: Ricky Gonzales, Director of Finance, ASM Globa Date Expected to be Corrected: July 1, 2022 SD 2022-001 PERIOD OF PERFORMANCE Recommendation: Only allowable costs incurred during the period of performance should be charged to the federal award. Supporting documentation should be reviewed in conjunction with the grant agreement and other applicable compliance requirements including statutes and uniform reporting requirements for restrictions, limitations, and conditions pertaining to the grant to minimize the amount of disallowed costs. Corrective Action: Management concurs with the suggestion. Grant personnel has been reminded to review supporting documentation in conjunction with the grant agreement and other applicable compliance requirements including statutes and uniform reporting requirements for restrictions, limitations, and conditions pertaining to the grant to minimize the amount of disallowed costs. Responsible Party: Cindy Anderson, AVP, Financial Services, EFSC Accounting Date Expected to be Corrected: October 10, 2022

Corrective Action Plan: In September 2022, DSHA implemented new processes for preparing and submitting ERA reports to U.S. Treasury. A third party technical assistance provider now has access to the UST Reporting portal, and coordinates with DSHA program staff to collect data to prepare report submissions. After reporting fields have been populated in the UST Portal, the DSHA Director of Policy & Planning reviews, certifies, and submits reports to UST. DSHA is coordinating with this technical assistance provider to ensure that a record of reporting information is retained after reports are submitted. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: September 2022

2022-006 Special Tests and Provisions ? Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate student programs and program beginning dates reported to NSLDS. The financial aid office cross-references program information within the student information system. Name(s) of the contact person(s) responsible for corrective action: Grant Pollard, Director of Financial Aid Planned completion date for corrective action plan: 11/1/2022

2022-003 Reporting Condition: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports: 1. All reports lacked evidence of proper review and approval by authorized individuals before submission of the report to the ED. 2. The Quarterly Student report for the period ended March 31, 2022 was not submitted in a timely manner. 3. The Quarterly Institutional report for the period ended September 30, 2021 was not submitted in a timely manner. 4. The Quarterly Institutional report for the period ended March 31, 2022 was not submitted in a timely manner. Correction: With respect to item #1, internal controls will be implemented for a second review of all quarterly reports by a member of the business office to verify accuracy before being submitted to the Department of Education and uploaded to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021. Items #2-4 reference reports that were not reported in a timely manner. Reminders in the calendar have been created to ensure completion of the reports. Information has also been shared with the College webmaster as to when reports need to be uploaded for timely submissions. Internal controls will be used to verify accuracy of data with the financial aid office, but also a final review that shows actual submission of the reports to the Department of Education and to the EWC website. This correction is being offered for a second year in a row due to the timing of when the FY21 audit was completed. The FY21 audit was completed August 17, 2022, which was more than 8 months past the normal completion time frame due to the cyber event that occurred in June 2021.

2022-004 ? Allowable Costs/Activities Allowed or Unallowed: Indirect Cost Name of Responsible Individual(s): Pamela Aguilera, Chief Financial Officer. Corrective Action: Safe & Sound?s Finance team implemented policies and procedures to ensure the indirect cost rate is calculated based on modified total direct costs, which excludes amounts over $25,000 for subawards. We updated our formulas to ensure that we properly calculated indirect costs on a monthly basis, ensuring the exclusion of subawards over $25,000. Date Completed: 7/31/2023