Corrective Action Plans

Finding 2022-003 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Testing and Mitigation for Rural Health Clinics FFAL #93.697 Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Period of Performance Finding Summary: The Facility's expense tracking spreadsheet which identified the expenses claimed under the federal program as allowable costs included three expenses which related to a future period. The Facility also claimed the cost of eleven chairs which had been returned to the third-party vendor during November 2022. A formula error was also identified within the calculation of clinic salaries and fringe benefits claimed under the federal program which was based upon a prorated basis of COVID related clinic visits as a percentage of total clinic visits. The Facility had multiple individuals identifying and compiling eligible expenses; however, the Facility's review and approval process over the Facility's expense tracking spreadsheet was not formally documented. Responsible Individuals: Phillip Husher, CFO, Freeman Regional Health Services Corrective Action Plan: We understand that future expenses and expenses for the chairs returned cannot be claimed under FFAL#93.697. We feel this will not require us to return funds to the Department of Health and Human Services as other eligible expenses qualifying under the COVID-19 Testing and Mitigation for Rural Health Clinics Program FFAL #93.697 were available. We know and understand the importance of reporting accurate information. We will have a formal review and approval process documented for future submissions. We agree with findings reported above. Anticipated Completion Date: December 31, 2023

Funds Spent After Award Ended Department Name: Health and Human Services Contact Name / Telephone Number of Person Responsible for CAP: Sheryl Plummer - (984) 236-5353 The Division of Mental Health, Developmental Disabilities, and Substance Use Services is in the final phase of filling the vacant Business Manager position within the Budget and Finance section. This position will be responsible for updating policies and procedures to include a detailed review process for processing grant expenditures. The policy will include a process for grant expenditure review during the 90-day liquidation (closeout) period for the grant. This process will consist of verifying grant expenditures and/or grant payment reclassifications has sufficient supporting documentation to be processed. The Division?s Budget and Finance section will also implement secondary review and approval processes for expenditures paid during the grant closeout period. Anticipated Completion Date: December 31, 2023.

U.S. Department of Education Education Innovation and Research CFDA #84.411C Activities Allowed Allowable Costs Period of Performance Material Weakness in Internal Control Condition: One out of 19 non-payroll expenditures tested lacked the required signature of the Director of Fiscal and Business Operations. Cause: Due to an oversight by CFA, the signatures of both the Director of Fiscal and Business Operations and the Manager of Business Operations were not present on the expenditure documentation. Management?s Response and Corrective Action Plan: Staff will ensure that both staff sign all expenditure documents. Responsible Individuals: Amanda Burke, Jessi Black Anticipated Completion Date: 3/23/23

CFDA Numbers: Various Program: Student Financial Assistance Cluster Corrective Action: The Registrar's Office has implemented a comparison process where graduates are verified against the National Student Clearinghouse grad only file. Implementation Date: 8/21/22 Corrective Action: The Registrar's Office has implemented a process to verify SSNs on record and correct student records. Implementation Date: 1/20/22 Corrective Action: The Registrar's Office will develop a business process to review term withdrawals for program/campus level discrepancies. Implementation Date: 6/12/23 Contact Person: Scott Campbell and Amanda Fijal

Recommendation In cases where grants require that the non-Federal match be proportionately met throughout the grant period, the Village should implement controls to identify such requirements and controls sufficient to track compliance with said requirements. If there are construction delays, the recommended action would have been to request an extension. Management Response Corrective Action: The Village recognizes the need for improved oversight of its grant-funded capital projects and has hired a full-time Grant Writer/Administrator who will work in conjunction with the Clerk and Finance Director to monitor grant activities, submit reports and requests for payment in a timely manner, and ensure all program requirements are met. Village staff will develop a grant project report template in order to track detailed information for each project, including local match requirements. Due Date of Completion: June 2023 Responsible Party: Finance Director and Village Clerk

Finding: 2022-001 Name of contact person: Jennifer Alden, CFO Corrective Action: While proper review was performed, previous policy did not require the review to be documented. A signature and date line will be added to all schedules related to federal awards for management to document review. Proposed Completion Date: Immediately

Finding 2022-001: Special Tests and Provision ? Return to Title IV Funds Corrective Action The University has reviewed the process and controls related to the return to Title IV requirement. The responsible department has implemented controls to ensure that the correct dates are used and returns are made within the 45 day requirement. Anticipated Date of Completion: June 2023

Finding 2022-004: Period of Performance (Significant Deficiency) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: 2 CFR Section 200 defines the period of performance as the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per 2 CFR Section 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. Condition: During the year ended December 31, 2022, FCE had seven grants under ALN 19.040, which supported the same projects and programs which had different periods of performance. We noted that costs totaling less than $25,000 were incurred outside the period of performance for two of the grants under ALN 19.040. Cause: FCE has no accounting policies and procedures in place to provide guidance to management on requirements related to accounting for federal awards in accordance with the Uniform Guidance. Effect or Potential Effect: FCE charged costs outside the period of performance for two grants under ALN 19.040. Recommendation: FCE should develop accounting policies and procedures to provide guidance to management regarding the proper internal controls over both financial reporting and compliance with federal awards. Action Taken: FCE acknowledges the discrepancy with respect to Period-of-Performance reporting, and the recommendation to develop accounting policies and procedures for proper financial reporting and compliance with Federal awards. FCE will develop and implement formal accounting policies and procedures to correct this deficiency.

PCC's Federal Grant Compliance Policy has been updated to ensure that the Development and Finance Departments will discuss with HRSA Program Officers all capital and other awards to obtain their concurrence and approval prior to any capital or other grant award draw. This will prevent miscommunication on unallowable costs for those grants.

Grants will be reconciled to ensure that all annual expenditures meet the grant budget and outcomes. The accounting and grants/foundation offices will work in partnership to ensure compliance. All documentation will be on file with the grants. The accounting administration will ensure this is done and the process has already started in FY23.

Corrective Action Plan: The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. Scheduled Completion Date of Corrective Action Plan: June 30, 2023 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

2022-001 One expenditure was not within the applicable budget period required by the University. Personnel Responsible for Corrective Action: Dana Funderburk, Vice President for Finance/CFO, and Monnie Harrison, Controller - Accounting Services Anticipated Completion Date: The corrective action plan will be implemented by June 30, 2023. Corrective Action Plan: Recognizing this expense was monitored through the internal control framework and still resulted in a human error, the proposed corrective action plan will focus on two areas: correcting the cost to the appropriate budget period, and coaching the members of the control system regarding the period of availability, specific to contractual services, membership services, and subscription services that are delivered over time to heighten awareness.

HARFORD COUNTY, MARYLAND CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Harford County, Maryland respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT None were reported. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF TREASURY 2022-001 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend the County strengthen and enforce its internal controls to ensure only allowable expenditures are charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The unallowed expenditure was moved out of the ARPA grant. The expenditure is being paid by County funds. All ARPA expenditures since July 1, 2022 (FY2023) have been reviewed to ensure they are allowable expenditures. Any expenditures that were not in compliance were moved from the grant to be paid by County funds. Name(s) of the contact person(s) responsible for corrective action: Robert Sandlass Planned completion date for corrective action plan: 11/30/22

Corrective action plan: The Federal Funds Instruction Guide will be revised to require that PCAs associated with closed grants are inactivated by the end of the approved close-out period. Budget and Planning management will discuss the revised guidance with staff to ensure proper implementation. TCEQ will implement the Centralized Accounting and Payroll/Personnel System (CAPPS) in September of 2023; grant numbers will include beginning and ending dates at the time the grant is created and will not require inactivation. TCEQ will ensure thorough documentation of its internal controls and the associated staff roles and responsibilities and will conduct periodic reviews of its controls. Implementation date(s): April 11. 2023 for update of the Federal Funds Instruction Guide and training staff. CAPPS: September 1, 2023. Responsible Persons: TBD, Federal Funds Section Manager; Stephanie Robinson, Assistant Deputy Director of Budget and Planning Division; Jene Bearse, Deputy Director of Budget and Planning Division

Corrective action plan: DPS will update the profile setup process in CAPPS to ensure the Service/Receipt Date Indicator box is checked in CAPPS on all profile setups relating to Grants. DPS Grants staff will receive training on how to fill out a Profile Setup Form to ensure the Service/Receipt Date Indicator Box is checked at the time the project is setup in CAPPS. The Grants staff will run a monthly report from CAPPS to see if all active projects have the service date indicator box checked. Implementation date(s): March 1, 2023 Responsible persons: Grants Manager, Deputy Administrator, Financial Reporting

Name of federal program: Block Grant for Prevention and Treatment of Substance Abuse Federal Assistance Listing: 93.959 Federal Agency: U.S. Department of Health and Human Services Pass-through entity: Tennessee Department of Mental Health and Substance Abuse Services Name of Person Responsible: Mary Linden Salter Corrective Action Plan: Management will put together a list of Monthly, Quarterly and Yearly anticipated invoices for year end. This list will be used at year end to check against payments/checks going out. Any invoice not received by Junes Month End will be investigated, to help insure they are received and paid before closure of the Month. During the following Months after Year End, management will pay closer attention to Invoice Dates during signing of checks to ensure if a late invoice comes through it is caught and placed in the correct year. Anticipated Completion Date: Management will be implementing the new procedure for the upcoming June 30th 2023 Year End.

CORRECTIVE ACTION PLAN October 10, 2022 Department of the Treasury ? CDFI Fund Grant Tampa Bay Federal Credit Union respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Doeren Mayhew Audit period: July 1, 2021 ? June 30, 2022 The findings from the June 30, 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: Establish control procedures to identify, track and reconcile eligible loans deployed during a grant performance period. Action Taken: Since the date of the exit conference, to address the internal control issue noted, we have created reports from our loan servicing systems and initiated procedures in which to identify and track eligible loan deployments on an individual loan basis. These totals will be reconciled to the loan deployments (financial products) reported annually on the Performance Progress Reports.

Finding 2022-003 Condition During the current year, the Organization submitted several of their draw requests to one of its funding agencies past the 45-day requirement. Per the grant agreement, any requests submitted beyond this timeframe can be denied for reimbursement at the discretion of the granting agency. Corrective Action Plan We understand the auditor?s comments and the following action has been taken to resolve the situation. Procedures have been developed and implemented to ensure that grant draw requests are prepared, reviewed and submitted on a timely basis in accordance with the grant agreements.

Responsible Official?s Response: Management will file the initial project and expenditure report by December 31, 2022 and will submit all required subsequent reports by their applicable due dates.

The Darke County Educational Service Center?s management will continue to review payroll calculations and believes this was an isolated error.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Wendy Marples, County Auditor Contact Phone Number: 812-338-2142 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All future reporting of the Coronavirus State and Local Fiscal Recovery Funds will be reviewed for accuracy by a second staff member of the Auditor?s office prior to submission. The report will be signed and dated by both the preparer and reviewer. All documentation will be maintained to help prevent any future inconsistencies. Anticipated Completion Date: April 2024

Finding 2022-005 Criteria or Specific Requirement: CFDA 14.872; US Department of Housing and Urban Development; Public Housing Capital Fund; annual contributions contract number FW-7097; fiscal year ending March 31, 2022.Period of Performance in accordance with 24 CFR 905 and the PHA Annual and 5-Year Action Plan. Recommendation for Corrective Action: Establish and enforce controls over administration of CFP?s to ensure safe, sanitary, and affordable dwellings are maintained for the purpose of serving families of low-income status in accordance with 24 CFR section 905. Views of Responsible Officials: We will review existing control procedures to correct these deficiencies. We are currently working with contractors to complete improvement projects in a timely manner. We will also provide increased supervision and training over the administration of this area. Planned Corrective Action/Action Taken: We will review existing control procedures to correct these deficiencies. We are currently working with contractors to complete improvement projects in a timely manner. We will also provide increased supervision and training over the administration of this area. We anticipate a complete resolution of this type of error by December 31, 2022. Anticipated Completion Date: We will have this resolved by December 31, 2022 Auditors Evaluation of Auditee Comments: Management?s comments in relation to its corrective action plan appear reasonable, valid, and supported with sufficient, appropriate evidence. If the Oversight Agency has questions regarding this plan, please call Clarice Sneed, Executive Director, at (870)295-2691.

Corrective Action Plan Finding 2022-001- Significant deficiency in internal controls over compliance: The school recognizes that we have a weakness in our control procedures. The School will strengthen our control procedures for Federal Grants by thoroughly reviewing the grant requirements and training staff involved with the grant process. The federal grant coordinator will review the Compliance Supplement and Uniform Guidance and inform staff team members of the requirements. The grant team will review significant transactions to insure proper procedures are followed. The team will also meet on a regular basis to discuss the grants. Responsible Party: Tracie Kennedy, CEO Kristi Courter, Federal Grant Coordinator Completion Date: March 1, 2023

2022-024 Improve Controls over Period of Performance Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Behavioral Health and Developmental Disabilities (DBHDD) Corrective Action Plans: The Department will continue to improve the internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. The Department will update processes and procedures associated with period of performance requirements and provide training that outlines close-out processes associated with the specific grant awards. DBHDD will update the internal controls related to period of performance no later than June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Kenneth Ward, Director of Internal Audit Telephone: 404-884-5486; E-mail: kenneth.ward@dbhdd.ga.gov

Finding No. SA 2022-001: Late Submission of Closeout Reports Assistance Listing Numbers: 17.258, 17.259 and 17.278 Federal Program/Cluster Name: WIOA Cluster Federal Agency: U.S. Department of Labor Pass-through Entities: City of Los Angeles and Los Angeles Department of Workforce Development, Aging and Community Services Contract Number and Name: 1720-WF101-RD:WIOA Adult? 26921 1720-WF101-RD:WIOA Dislocated Worker ? 26921 1720-WF101-RD:Youth@Work?WIOA OSY? 26844 Compliance Requirement: Reporting Criteria or Specific Requirement Per OMB Compliance Supplement under the financial reporting requirement for ETA-9130, Financial Report (OMB No. 1205-0461), and per Code of Federal Regulations (CFR), Title 2, Subtitle A, Chapter XI, Part 200, Compliance Requirements, all ETA grantees are required to submit quarterly financial reports for each grant award they receive. Reports are required to be prepared using the specific format and instructions for the applicable program(s); in this case, Workforce Innovation and Opportunity Act instructions for the following: Statewide Adult; Workforce Statewide Youth; Statewide Dislocated Worker; Local Adult; Local Youth; and Local Dislocated Worker. A separate ETA 9130 is submitted for each of these categories. Reports are due 45 days after the end of the reporting quarter. Condition The closeout reports of the following programs for the performance period July 1, 2021 to June 30, 2022 were submitted beyond 45 days after the deadline: ? WIOA Adult Program ? submitted 59 days after the deadline; ? WIOA Dislocated Worker Program ? submitted 47 days after the deadline; and ? Youth@Work ? WIOA OSY ? submitted 45 days after the deadline. Cause and Effect The Organization had a major employee turnover during the year and had to resort to hiring a third-party accountant to assist in completing the audit requirements. As a result, the closeout reports were submitted late to the County. Questioned Costs None Recommendation We recommend that the Organization implement formal procedures to ensure that closeout reports are prepared timely and submitted within the deadline. Views of Responsible Officials and Planned Corrective Actions LA County noted that closeout reports were submitted late by CCD. In order not to increase potential overbilling, CCD fiscal and program staff meet regularly to reconcile invoices. The new accounting software also tracks budgets, goals and project deadlines. Person Responsible: Rhonda Rose and Federico Quinto, Jr. CPA CFE Position of Responsible Party: Acting Executive Director and Outsourced Accountant Anticipated Completion: October 2022