Corrective Action Plans

Action taken in response to finding: County department personnel changes have been implemented which address this deficiency. New department personnel have been properly trained by County Auditor staff as well as State grantor personnel to ensure correct grant reporting. Department supervising staff will monitor grant reporting documentation. All manual adjusting entries will be requested through the County Auditor’s office to ensure proper supporting documentation is provided. Name(s) of the contact person(s) responsible for corrective action: Dave MacDonna, Community Resources Director. Eric Black, Chief Deputy Auditor. Planned completion date for corrective action plan: October 2, 2023

U.S. Small Business Administration Eugene O’Neill Memorial Theater Center, Inc. respectfully submits the following corrective action plan for the year ended August 31, 2022. Audit period: August 31, 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—FEDERAL AWARD PROGRAMS AUDITS U.S. Small Business Administration 2022-001 Shuttered Venue Operators Grant – Assistance Listing No. 59.075 Recommendation: We recommend Eugene O’Neill Memorial Theater Center, Inc. design controls to ensure an adequate review process is in place to review the period of costs incurred to ensure costs are recorded within the financial statements as grant revenue in the proper period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review more closely to ensure costs are recorded within the financial statements as grant revenue in the proper period.. They also note that costs charged to awards are all award related and within the full award period. Name of the contact person responsible for corrective action: William Kuklinski, Controller and Tiffani Gavin, Executive Director Planned completion date for corrective action plan: October 2, 2023 If the U.S. Small Business Administration has questions regarding this plan, please call William Kuklinski or Tiffani Gavin at (860) 443-5378.

2022-004: Reporting - Timely Submission of Financial Reports – Material Weakness in Internal control over Financial Reporting and Noncompliance  The City recently hired a Finance Director and is working to fill the Controller position. Being fully staffed will assist in the timely completion of the City’s audit.  Anticipated completion: December 2023

The BOCC will develop internal control procedures to help ensure that federal grant funding is monitored more closely and that expenditures are verified to be in compliance with grant requirements. Future grant recipients will be required to have BOCC approval before expenditures can be turned in for payment. Grant recipients will also be required to have BOCC approval before depositing grant funds. This should ensure that all transactions are in compliance with grant requirements.

Finding 2021-011 - Repeat of 2020-008; Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Description of Finding: The School District was unable to provide supporting documentation for all expenses. District Position: The School District concurs with the finding. Corrective Action to be Taken: The District has appointed a Federal Programs Coordinator who is familiar with the Single Audit requirements of the Uniform Guidance. Management has restructured its business office and is working with third party consultants in conjunction with the Federal Programs Coordinator to implement policies and procedures to properly document federal grant expenditures. These policies and procedures include maintaining proper source documentation for federal award program activities and reconciling that documentation with amounts recorded in the general ledger within the District’s accounting software on a consistent basis. Timetable for Implementation: Implemented for 2022-2023 fiscal year Monitoring to be Performed: The Receiver and Business Manager will monitor timely and continued implementation. Responsible Person with Scope of Authority: Receiver and Business Manager

We will implement control procedures to ensure compliance with requirements.

2021-003 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 Performance Reports and Federal Financial Reports established by the OEA in their Notice of Award granted on June 6, 2020. 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

Item 2021.007 – Period of Performance Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • Conduct a pre-approval of expenditures, verifying that the expense is allowable under the grant terms and falls within the period of performance. • Utilize a pre-approval form that includes details of the proposed expenditure, its necessity, and confirmation in the form of authorized signatures, that is within the grant period. • Require all relevant supporting documentation with the date the expense was incurred, ensuring it falls within the grant’s period of performance. This is further reviewed by the CFO who will verify that the expenditure meets all requirements and is then able to record it in the accounting system. • Conduct regular reviews of expenditures to ensure compliance with the grant period and maintain audit trail. • Review these procedures annually to ensure ongoing compliance with the grant’s period of performance.

Item 2021.007 – Period of Performance Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • Conduct a pre-approval of expenditures, verifying that the expense is allowable under the grant terms and falls within the period of performance. • Utilize a pre-approval form that includes details of the proposed expenditure, its necessity, and confirmation in the form of authorized signatures, that is within the grant period. • Require all relevant supporting documentation with the date the expense was incurred, ensuring it falls within the grant’s period of performance. This is further reviewed by the CFO who will verify that the expenditure meets all requirements and is then able to record it in the accounting system. • Conduct regular reviews of expenditures to ensure compliance with the grant period and maintain audit trail. • Review these procedures annually to ensure ongoing compliance with the grant’s period of performance.

No corrective action taken.

No corrective action taken.

Finding Reference Number: MW2021-009 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2021: CUAHSI used a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2021 program income. CUAHSI staff missed the NSF filing deadline for declaring federal fiscal year 2021 program income by one day (submitted November 16th, 2021). 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 beginning in 2023 and appropriate staff and policies are in place to ensure 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

Assistance Listing Number21.019 Lack of Internal Controls Over Major Federal Programs Coronavirus Relief Fund Muskogee County has hired an internal grant administrator to assist in keeping the county compliant with all local, state, and federal requirements. Efforts will be made going forward to ensure that all grant funds are properly expended.

Assistance Listing Number 21.019 Lack of County-Wide Controls Over Major Federal Programs Coronavirus Relief Fund Muskogee County has hired an internal grant administrator to assist in keeping the county compliant with all local, state, and federal requirements. Efforts will be made going forward to ensure that all grant funds are properly expended.

The county will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.

FINDING 2021-007 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness, Other Matters The County did not have an effective internal control system to ensure compliance with the Reporting compliance requirement. Recipients were required to submit a one-time Interim report to the U.S. Department of the Treasury (Treasury). The County submitted the required interim report during the audit period. The County's process for the completion and submission of the Interim Report was that the County Auditor prepared the Interim Report based on the County's records, without a proper oversight or review process in place prior to submission. The Interim Report was determined to be materially misstated. The County understated the December 31, 2019, Base Year Revenues by $660,302. 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. The preparer and reviewer will sign/initial to document the review process. Anticipated Completion Date: We will begin requirement a review prior to submission as of November 21, 2024.

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 an 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.

Period of Performance: The College partially agrees with the finding. During the audit fieldwork, the College was not able to provide the supporting documents to substantiate the allowability of the charges for the grant. September 30, 2022 Stevenson Kotton VPBAA Valyn Chonggum FABS Interim Director

We will research the compliancerequirements for each Major Federal Grant the County receives. Withthe compliance requirements in mind, we will establish policies and procedures to satisfy those requirements and practice oversight over federal grant activity.

The Officers of Alfalfa County will meet to discuss the County-Wide Controls over the administration of Major Federal Programs. After discussing and gaining input from all those involved, written procedures will be approved and distributed.

Finding 2021-006: Subrecipient Monitoring 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: 1640791 (9/15/2016 – 8/31/2022) Condition: During our audit work over subrecipient monitoring, we were unable to verify that pre-award risk assessment procedures were performed. It is our understanding that AAPT has ongoing relationships with these subrecipients and evaluation of these subrecipients' risk is a continual process; however, these procedures were not documented. Views of Responsible Officials and Planned Corrective Actions: Management will continue to perform risk assessment procedures and will thoroughly document the processes and evaluations. Anticipated Completion Date: 12/31/2022 Responsible Official: Michael Brosnan, CFO

Finding 2021-003: 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: 1524963 (11/1/2015 – 9/30/2021), 1812860 (9/1/2018 – 8/31/2020) Condition: The year-end schedules for federal grants receivable, for 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 $80,978 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

Corrective Action Plan For Year Ended December 31, 2021 Contact Person: Jason Feldhaus, Executive Director jason@thresholdcoc.org 402.290.6106 FINDING 2021-003: Allowable Costs All receipts for expenses of the Organization are attached to the transaction in bill.com, which then gets transferred to the accounting system, QuickBooks Online. Additionally, backup for landlord payments is saved in a separate folder for reference. Prior to payment approval of an expense, the approver confirms there is adequate backup for the allowable costs. A policy will be included in the updated Financial Policies and Procedures manual in 2024. Reasonable completion date: Already implemented (October 31, 2024 for policy updates) Responsible Party: Jason Feldhaus, Executive Director

Finding No.: 2021-024 AL Program: 17.225 - Unemployment Insurance Area: Eligibility Questioned Costs: $1,131,117 Contact Person(s): Zachary Taitano, PUA Program Manager, DOL Corrective Action Plan: Condition 1: CNMI DOL agrees with audit findings for Condition 1 for all three Application IDs indicated, as upon further review, Social Security Cards were not on file for claims identified. However, per the Benefits Rights Information (BRI) Handbook, and PL 116-136 CARES Act, claimants were only required to provide their full social security number. For each claim, the full SSN of claimant is provided and self-certified, on both the Initial Application and in each Weekly Certification. Condition 2: CNMI DOL agrees with this finding. Notably, this issue was identified and addressed through Fiscal Year 2020’s Single Audit. OPC 590093 was initiated on July 31, 2020 to send a Letter of Determination via the HireMarianas Portal’s internal messaging system. Moreover, the OPC also requested for all future payments that a Letter of Determination be issued once a payment is generated per user. Condition 3: CNMI DOL agrees with this finding, with respect to the SAVE Verification being necessary. However, upon further examination: Application ID 398353: The applicant has a SAVE verification response uploaded to their HireMarianas Portal dated 05/23/2022. Moreover, upon a further review of the USCIS-SAVE Database, the other Application IDs identified did not have a SAVE Verification initiated upon initial clearance. CNMI DOL has initiated a SAVE Verification for the remaining 3 users. The results are as follows: Application ID 158179: This applicant is a Green Card holder and the SAVE response was returned immediately. A copy of the SAVE verification response for this user was uploaded to the applicant’s HireMarianas Portal on June 24, 2024. A Green Card holder meets the definition of a qualified alien. Application ID 111798: This applicant is a CW-1 VISA holder. A SAVE verification was initiated on June 24, 2024 with the WAC Number indicated on the I-797A (Notice of Action) Form for the relevant period in time. A response was returned on July 5, 2024 stating that the applicant is employment authorized. Application ID 399118: This applicant is a CW-1 VISA holder. A SAVE verification was initiated on June 24, 2024 with the WAC Number indicated on the I-797A (Notice of Action) Form for the relevant period in time. A response was returned on July 5, 2024 stating that the applicant is employment authorized. While CNMI DOL agrees with the fact that SAVE Verification was necessary prior to payment disbursement, it is important to note that all the indicated applicants were indeed qualified aliens per the PUA Program Guidelines   This issue was identified and addressed through Fiscal Year 2020’s Single Audit. OPC 590093 was initiated on July 31, 2020 to send a Letter of Determination via the HireMarianas Portal’s internal messaging system. Moreover, the OPC also requested for all future payments that a Letter of Determination be issued once a payment is generated per user. Condition 4: CNMI DOL agrees with this finding. Upon additional review of the current overpayment log, the Department was able to recollect a total of $19,354.17 from the applicants that were noted in the initial listing provided to the auditors. This leaves the updated remaining overpayment balance for FY 2021 at $1,128,975.35. Auditors were provided with the documentation to substantiate this on 06/24/2024. Recollection efforts are Ongoing. Proposed Completion Date: Ongoing

Management acknowledges the findings and has implemented a corrective action plan to enhance compliance with Federal awards. This plan includes developing Standard Operating Procedures (SOPs) for grant management activities, identifying and documenting existing internal controls, and maintaining constant communication with stakeholders to prevent material noncompliance. Additionally, PREPA will provide training to staff on the new SOPs and establish a monitoring mechanism to continuously assess and improve the effectiveness of these controls. The corrective action plan, supervised by Mr. Ezequiel Nieves from the PREPA Disaster Funding Management Office, is expected to be completed by July 2025. Management is committed to addressing deficiencies, ensuring that processes and controls are robust and effective, and that Federal awards are managed transparently and in full compliance with all regulatory requirements. Effective June 1, 2021, the Authority transitioned the management and operation of its transmission and distribution network as well as certain back- office functions, including billing, collections and accounting, to a third party. The third-party operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. Management will work to address these findings with the assistance of the third-party operators, where applicable. Also, effective July 1, 2023, the Authority transitioned the management and operation of its generation assets as well as certain back- office functions to a third party. The thirdparty operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. In addition, the Authority will also be implementing and monitoring corrective actions taken by the new generation segment operator. Contact Name Responsible for Corrective Action Plan - Ezequiel Nieves Estimated Completion Date - July 2025