Corrective Action Plans

In May 2022, a new CFO was hired and new procedures put in place. Both the CFO and Accounting Manager both have reviewed eligible expenditures and loss revenue to ensure entity does indeed qualify for the full amount of funding, regardless of the information that was submitted on the respective reports.

In May 2022, a new CFO was hired and new procedures put in place. Both the CFO and Accounting Manager both have reviewed eligible expenditures and loss revenue to ensure entity does indeed qualify for the full amount of funding, regardless of the information that was submitted on the respective reports.

Finding 2021-006 Reporting - Timely Submission of Financial Reports – Material Weakness in Internal Control over Compliance and Noncompliance Name of Contact Person: James Wilson, Borough Manager Corrective Action Plan: The Borough is currently in process of catching up on audits with the goal of completing the FY 2023 audit timely. Completion Date: March 2024

Finding 2021-005 Activities Allowed and Unallowed, Allowable Costs, Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Name of Contact Person: James Wilson, Borough Manager Corrective Action Plan: The Borough is currently undergoing an upgrade in record retention policies and procedures. Completion Date: December 2023

Title 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters), Officials and employees tasked with the responsibility of expending federal FEMA funds will attend training and seminars offered by OSAI, OEM, and Muskogee Creek Nation to better understand the guidelines. Information received will be communicated to the other officials at the quarterly meetings, Anticipated Completion Date 6/30/23, Responsible Contact Person Board of County Commission Chairman - James Yandell

Tile 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters), Planned Corrective Action Officials and employees tasked with the responsibility of expending any federal funds will attend training and to better understand the guidelines. Information received will be communicated to the other officials at the quarterly meetings, Anticipated Completion Date 6/30/23, Responsible Contact Person Board of County Commissioner Chairman - James Yandell

Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over compliance with Payroll - Significant Deficiency Recommendation: The auditor recommends that the Entity implement controls for documenting and retaining information to indicate the Entity follows the requirements over 2 CFR section 200.430(i), and that alll pay rates be reviewed for approval and propriety. Action Taken: EPHCC will implement additional controls to ensure the following: 1. All employees must submit an approved timesheet or time and effort for each pay period. 2. All payroll transactions for staff from staffing agencies need to be reviewed by the accounting manager to ensure invoice has correct rate and that staff is paid for all hours worked on timesheet. 3. Upon hiring staff from staffing agencies, EPHCC shall document and retain information that all pay rates are reviewed byt the CEO for approval and propriety. Responsible Official: Chief Financial Officer, Lizabeth Romero Timeline for Implementation: Effective by May 2023

Finding No.: 2020-009 CFDA Program: 93.268 Immunization Cooperative Agreement Area: Period of Performance Questioned Costs: $4,343 Contact Person(s): Program Administrator, Director of DGFI, and Chief Financial Officer Corrective Action Plan: CHCC does not concur the findings and the questioned cost. The transaction cited were for emergency repairs of Vaccine Refrigerators. The repairs were done within the period of performance ending June 30, 2020 ($2,990 was for Service date of December 20, 2019; and $1,353 was for service date February 28, 2020). No purchase order was prepared for the emergency service. A ratification memo was approved for payment processing by the Chief Financial Officer and the Chief Executive Officer. CHCC believes that the repairs on the Refrigerators that are used to store vaccines are reasonable and necessary, especially during the period wherein CHCC was responding to the COVID-19 Proposed Completion Date: On-going

The County will include discussion of all required compliance requirements for each federal program presented in our Officers’ meetings.

I am aware of the audit findings involving FEMA Disaster 4315. I apologize for the delayed response letter. On behalf of Dewey County District 2, we want to assure you we are here to help and assist in anything you or your office may need from myself, or from any District 2 employee.

Implement or strengthen review procedures to ensure all costs charged to federal awards are incurred within the approved performance period by February 28, 2026. Train personnel responsible for grant accounting on the importance of verifying dates of service, invoice dates, and award period limitations by March 31, 2026. Consider implementing system-based controls that prevent posting expenditures with dates outside the award period, including automated alerts and approval workflows by April 30, 2026. Establish a grant closeout checklist that includes verification of all expenditure dates and identification of any costs incurred after the period of performance by May 31, 2026. Conduct monthly reviews of pending expenditures during the final quarter of each award period to identify and prevent late charges by June 30, 2026.

Finding Reference Number: MW2020-009 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2020 program income. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI uses a single payment gateway to segregate payments appropriately per event and per grant. Program income for subsequent years has been reported to NSF annually 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

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2020 program income. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI uses a single payment gateway to segregate payments appropriately per event and per grant. Program income for subsequent years has been reported to NSF annually 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

2020 ‐ 001: Material Weaknesses in Internal Controls over Compliance— Activities Allowed and Allowable Costs for Non-payroll expenses, Period of Performance, Reporting, and Special Test and Provisions. Compliance requirement Corrective Action Activities Allowed/Allowable Costs and Period of Performance Microsoft D365 was implemented in 2022 as the ERP system for Dairyland Power. Microsoft D365 will allow for project tracking ensuring appropriate approval workflows specific to federal assistance programs. Workflows will be set to ensure costs are routed to personnel who have authority to approve and also have knowledge of cost allowability as stipulated by the federal award. The system also supports historical data requirements by allowing retention of documents withing the system at the transaction level. The use of the Microsoft D365 ERP will ensure the evidence of approval for non-payroll expenses would be appropriately logged and retained within the system. This corrective action is currently in place. Reporting and Special Test and Provision Dairyland Power has recently established Grant Policies to ensure that internal processes are managed in compliance with federal awards. An Allowable Cost Policy was created to clearly define roles and responsibilities for the management of federal awards and also identifies the review and approval process of reimbursement requests/reports. A multi-layer approval process for the approval of reimbursement exists. The Project manager, in coordination with the Grant Specialist and the Compliance Team, will review federal project costs and prepare reimbursement reports per the instructions. The reimbursement request/report will then be submitted to the Grant Manager, who will review the reimbursement request/report for cost allowability and completeness. Upon approval from the Grant Manager, the reimbursement request will be forwarded to the Treasury Manager who will review, approve, and submit the request through the proper submission channel by the deadline. Evidence of review will be saved for documentation purposes. Dairyland Management will conduct an annual review of the established Grant Policies or reassess them when necessary. Employees at Dairyland who participate in the federal award process will be provided with training on the Grant Policies. This corrective action is currently in place. In addition to the above corrective action, Dairyland Power has also engaged an external audit service to conduct a review of the design and operating effectiveness of Dairyland’s grant process internal controls. The purpose is to provide Dairyland with a comprehensive assessment of the existing Dairyland internal control processes and policies related to federal awards. Expected completion of this audit is January 2025. Anticipated Completion Date — January 2025 Responsible Party — Tim Lightfoot, Controller

Finding 2020-003: 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: 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023) 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 $73,057 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by April, 30,2024 The remaining balance was earned in 2021. 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: October 15, 2024 Responsible Official: Michael Brosnan, CFO

Finding 2020-006: 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)Cause: AAPT's internal policies and procedures governing risk assessment on subrecipient was not performed. 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

Hyde Leadership Charter School – Brooklyn will implement procedures to track and manage expenditures reimbursable by federal awards. The accounting system will be updated to track and capture federal expenditures separately from general expenditures. Management and Hyde Leadership Charter School – Brooklyn’s financial service provider will review federal expenses incurred prior to submitting for reimbursement.

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 non-compliance. 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 third-party 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. Mr. Ezequiel Nieves - PREPA Disaster Funding Management Office July 2025

Finding 2020-006: Subrecipient Monitoring Federal Programs: Research and Development Cluster: Stem +C Cause: AAPT's internal policies and procedures governing risk assessment on subrecipient was not performed. 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: December 17, 2021 Responsible Official: Michael Brosnan CFO

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, 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.

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 No 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 fall 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 it 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 review of expenditures to ensure compliance with the grant period and maintain audit trail • Review these procedures annually to ensure the ongoing compliance with the grant’s 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 No 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 fall 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 it 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 review of expenditures to ensure compliance with the grant period and maintain audit trail • Review these procedures annually to ensure the ongoing compliance with the grant’s period of performance

2020-108 Lack of Controls over Costs Submitted for Reimbursement Condition: The Organization included an invoice for reimbursement under the program for which a vendor credit memo for the full amount of the invoice had been received due to miscoding of the credit memo to the correct COVID-19 class on the general ledger. In addition, the Organization did not include an applicable invoice for COVID-19 expenses for reimbursement due to the same miscoding of the COVID-19 class to the general ledger. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. Management understands the importance of reviewing the posting of credit memos or applicable invoices to ensure they are posted correctly. We will update our policy to include a process for review of credit memos prior to posting. The planned corrective action for this finding is currently in the process of development, approval, and implementation. Person Responsible for Corrective Action: Robert Thompson, Chief Operating Officer Anticipated Completion Date: March 1, 2023

2020-107 Lack of ACH Payment Review and Approval Condition: Payments are not reviewed prior to ACH payments. The Organization has no documented policies and procedures for handling the processing and review of ACH payments. Corrective Action Planned: : The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. Management understands the importance of reviewing the posting of credit memos or applicable invoices to ensure they are posted correctly. We will update our policy to include a process for review of credit memos prior to posting. The planned corrective action for this finding is currently in the process of development, approval, and implementation. Person Responsible for Corrective Action: Robert Thompson, Chief Operating Officer Anticipated Completion Date: March 1, 2023

Finding: 2020-003 - Period of Performance Significant Deficiency in Internal Controls Over Compliance and Instances of Noncompliance Recommendation: The Organization should implement controls to ensure all expenditures allocated to grants are for costs incurred during the specified period of performance. Corrective Action Plan: In January 2021 the WWBC engaged with HighPoint CPA, a non-profit fiscal management firm that processes our accounting, payroll and/or tax needs. HighPoint CPA has implemented a new fiscal management system DEXT, that increases our grant management efficiency and tracking. The Executive Director meets the Monday before the monthly board meeting with the Board Chair and Treasurer to review financial statements and grant reporting documents in order to verify that they are free from material misstatement. In addition, the Finance and Audit committee meets the 2nd Tuesday of every month to ensure compliance. Anticipated Completion: January 2021 Responsible Party: Board of Directors and Executive Director