Corrective Action Plans

Finding Number: 2024-002 Condition: Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. Planned Corrective Action: ECDI has created a calendar for deadlines that has been shared between Development, Fiscal, and Program managers to ensure all deadlines are met. Multiple notifications are provided to these parties in advance of due dates. Contact Person Responsible for Corrective Action: Brian Barrett, Hudu Ahmed and Louisa Dallett Completion Date: March 1, 2025

Boston Public Schools will take a multi-step approach to ensure accuracy of spending to the grant award period. Anticipated Completion Date: January 31, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name{s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

– 84.425F Finding: Two errors were noted related to period of performance: 1) the lost revenue calculation was completed in October 2023, which was after the June 30, 2023 period of performance date; and 2) the District also spent money on expenses for the program in November 2023 and January 2024, which was after the 120-day liquidation period. Corrective Action Taken or Planned: The School will create and maintain a funding schedule according to the grant agreements. The schedule will be reviewed by various finance staff members for timing of grant reimbursements and deadlines. Contact person: Mike Stephens, Director of Accounting Status of finding – The above corrective actions will be implemented beginning April 1, 2025.

2024-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: Following consultation with the National Student Clearinghouse (NSC), guidelines were provided for handling various status change scenarios. These guidelines will enhance the accuracy of enrollment status change reporting, particularly for students with changes occurring before or after the subsequent enrollment file submission. Status changes are now being reported to the NSLDS in a timely and accurate manner, in accordance with the NSC guidelines. The University has also implemented a reporting timeline and review protocols to ensure status changes are reported to the U.S. Department of Education’s National Student Loan Data System (NSLDS) in a timely manner. Additionally, the University will collaborate with its Information Technology Services and representatives from the NSC and NSLDS to verify the accuracy of the file layouts and the data flow of the information provided. Responsible University Personnel: John Perry, Executive Director of Financial Aid/ Scholarships and Registration; Timothy Carroll, Registrar. Anticipated completion date: Partially implemented. The University is collaborating with its Information Technology Services and representatives from the NSC and NSLDS on accurate reporting of the program start date, which is expected to be completed during Fiscal Year 2026.

Department of Justice Federal Financial Assistance Listing #16.582 Activities Allowed and Allowable Costs, Period of Performance Significant Deficiency in Internal Control over Compliance Finding Summary: Our testing over activities allowed and allowable costs and period of performance identified five employee timecards that were not reviewed and approved by an individual other than the employee. Responsible Individuals: Jamie Schaefer, John Neth Corrective Action Plan: The organization will review and strengthened the controls surrounding activities allowed and allowable costs as well as period of performance compliance. Avera Health has updated its enterprise resource planning system to Workday, which utilizes an effort certification system. Within the effort certification system, Individuals will self-report/certify their time, the certification will then route to the specific grant management staff instead of the cost center supervisor. Anticipated Completion Date: June 30, 2025

FINDING 2024-005 (Auditor Assigned Reference Number) Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Julie Remschneider Contact Phone Number and Email Address: julie.r@nn.k12.in.us, 219-285-2228 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will ensure the Special Education Co-op will have controls in place to make sure payments are made within the period of performance. Anticipated Completion Date: September 30, 2025

FINDING 2024-006 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Contact Person Responsible for Corrective Action: Carolyn Wallace Contact Phone Number and Email Address: 812-738-2168, extension 102 and WallaceC@shcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Documentation of review for adjustments/corrections, including the period of performance, will be maintained for auditor review. Anticipated Completion Date: June 15, 2025

Condition: Of the 40 samples included in our sample selected for testing in the Research and Development Cluster (R&D), the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Planned Corrective Action: The university has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period. Contact person responsible for corrective action: Associate Controller, Brenda Lindberg Anticipated Completion Date: The new grants module, which includes grant billing and award calendar schedule became operational at July 1, 2024.

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was not consistently accurate. Corrective Action Plan: The Center has historically calculated the indirect amount using the same methodology over time. Given the small volume of patient receipts, the impact on the total indirect amount is minor. We believe that had we modified our calculations, we would have had enough modified total direct costs to cover the change in the calculation. The Center will modify all future calculations to ensure alignment. We will also review the fiscal year covered under this audit to understand what the impact of the change would have been on the split between cost types. Note that since we are midway through our next fiscal year, and we consider the differences minor, we have determined that we will correct for any future reimbursement requests, but will not modify prior reimbursement requests. Similarly, we will conduct a review of that fiscal year to determine the impact of the change and verify it is not significant. Responsible Individuals: Rusty Taylor, CFO Joe Carrington, Director of Financial Planning and Analysis Anticipated Completion Date: August 2025

Reference Number: 2024-013 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Federal Transit Cluster Assistance Listing Number: 20.500, 20.507, 20.526 Award Number and Year: VT-04-0021-01 (3/14/2013 – 6/30/2016) Compliance Requirement: Cash Management, Period of Performance Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend that VTrans review and enhance grant closeout procedures and internal controls to ensure that grants are closed out timely. We further recommend that VTrans review and enhance procedures and internal controls over cash management to ensure that cash draws are performed only against grants for which the period of performance has not expired. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The following factors contributed to the noncompliance: VTrans experienced staff turnover, at which point close out processes were missed in 2016. This resulted in a grant remaining with an open status in the TrAMS system well beyond the period of performance. During the 2024 review by program staff, a drawdown was inadvertently processed for this grant with the expired period of performance. At the time, VTrans lacked a formal, documented grant closeout process for FTA grants in the TrAMS system. Additionally, there was a breakdown in communication between the Accounts Receivable (AR) team and the Public Transit Program team regarding period of performance eligibility prior to processing the draw. VTrans has taken the following steps to strengthen internal controls and prevent recurrence of this issue: 1. Formalized Closeout Procedures: VTrans has implemented a structured grant closeout process for the AOT Public Transit Program that clearly defines responsibilities, timelines, and verification steps to ensure all federal awards are closed timely and in compliance with FTA requirements. This process assigns specific tasks to designated staff members and ensures that no drawdowns occur after the period of performance has ended. 2. Annual Period of Performance Review: VTrans has established and documented an annual review process for FTA grant periods of performance. This review has been formally integrated into the Agency’s Public Transit cash management procedures, ensuring that grant end dates are proactively monitored, and necessary extensions or closeouts are addressed before expiration. 3. Enhanced Communication and Documentation: VTrans has updated the internal Excel file used to facilitate communication between the Public Transit Program team and the AR team. The file now includes a designated column for period of performance, ensuring that all drawdowns are reviewed for eligibility before processing. This is also addressed in an update to the Agency’s Public Transit cash management procedure memo. VTrans will coordinate with FTA to determine the appropriate resolution for these funds. Any necessary repayment or adjustments will be completed in accordance with FTA guidance. At this time, FTA has not requested the funds be returned. Scheduled Completion Date of Correction Action Plan: All corrective actions will be implemented as of March 1, 2025. Contacts for Corrective Action Plan: Ross MacDonald, Public Transit Director ross.macdonald@vermont.gov

Reference Number: 2024-010 Prior Year Finding: 2023-008; 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding. 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. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. It should also be noted that the UI admin funds are considered ‘formula funds’ from the US DOL. We are expected to run this program year-round with no gaps in service or performance. The funding that we receive from US DOL is based on an antiquated formula that breaks down the amount that is budgeted by Congress between 52 state and territories. We generally do not receive enough funding for the entire year. Also, with the recent trend of Congress to utilize the tool of the Continuing Resolution our funding is often ambiguous until most of the program year is over. We have at times seen our funding cut once a budget had been passed by Congress even though there was only about 3 months left in the program year. We are still expected to run this program and ‘find other sources of funding’. This does make the adherence to the period of performance challenging. However, as we evaluate our internal controls and procedures over the coming months, we will make note of every opportunity to strengthen this function to ensure that all charges applied to program funds are relevant, within the period of performance of the award, and are correctly reviewed and signed. Scheduled Completion Date of Corrective Action Plan: April 1, 2025 Contacts for Corrective Action Plan: Chad Wawrzyniak, Financial Director II chad.wawrzyniak@vermont.gov

Reference Number: 2024-007 Prior Year Finding: No Federal Agency: U.S. Department of Defense State Agency: Vermont State Military Department Federal Program: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing Number: 12.401 Award Number and Period: W912LN2421001 (10/1/2023 – 9/20/2024) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Department agrees with this finding and will implement the following: • Update Accounts Payable Standard Operating Procedures to include instructions for determining the appropriate Federal Fiscal year for coding and paying vendor invoices. • Distribute updated procedures and train staff to ensure understanding of Period of Performance reporting requirements. • Update Vision query to include the Invoice Date field. Current reports used for preparing the SF-270 only include the Vision transaction date, therefore the preparer and reviewer are not able to determine the performance dates of individual transactions based on this report alone and rely on proper coding of the Class field during voucher entry. Adding the Invoice Date to the report will improve the department’s ability to QC the SF-270 for period of performance discrepancies prior to submission for reimbursement. • The Financial Director will perform quarterly audits of this Vision report to identify any improper reporting. Any errors identified will be corrected with a journal voucher and subsequently corrected on the next SF-270. Scheduled Completion Date of Corrective Action Plan: April 15, 2025 Contacts for Corrective Action Plan: Kim Fedele, Financial Director kimberly.fedele@vermont.gov

The process to determine students who withdraw during the semester has been updated to include running a withdrawal list through RGER weekly. The list will be given to the Financial Aid Counselors to work on Mondays. Part of the review will be to verify the start and end dates of the term used during the process. The Director or Assistant Director will review the lists and R2T4 forms (ROFW) to verify accuracy and timely processing.

Corrective action plan: Social Services Block Grant (SSBG) Actions Taken: HHSC Fund Management worked with Chief Financial Officer (CFO) Operations Support to develop a query to identify journal transactions that post in the CAPPS Financials General Ledger module prior to the start date of the project. This query has been run monthly since May 2024, and it was fully implemented as of August 31, 2024. Planned: Additional training on the review process for Accounting and Budget staff, and revisions to the process to emphasize meeting deadlines while new federal grants and old federal grant close out transactions occur. An expenditure transfer voucher (ETV) to correct reconciliation issue will be completed by CFO Budget staff. Block Grants for Community Mental Health Services (MHBG) Actions Taken: HHSC Fund Management will run the monthly query and take corrective action on any resulting journals prior to the close of the fiscal year. In addition, HHSC Fund Management/Cash Management does not draw federal funds past the liquidation date. These dates are denoted in their draw ledgers. Cash Management also sends a semi_x0002_monthly email during the fiscal year and a weekly email from mid-June through the end of July to HHSC Budget identifying transactions by fund source that should be cleared from the draw down report prior to the close of the fiscal year. HHSC Cash Management will continue to send the draw down clean up report and start the weekly emails the first week of June. HHSC Budget will complete any ETVs resulting from the draw down clean up report to HHSC Fund Management General Ledger for processing by July 15 to ensure the draw down accurately reflects federal expenditures for the SEFA population. Planned: Budget Management will revise the coordination process with Behavioral Health Services program financial staff administering MHBG to prioritize addressing encumbered balances on expiring block grant years at the beginning of the liquidation period and set deadlines for Program input on required financial adjustments to ensure sufficient time for processing. ETV to correct reconciliation issue will be completed. Implementation dates: February 28, 2025 Responsible persons: SSBG: Heather Nevill, Fund Management Director, Fund Accounting Raymond Jasik, Budget Director, CFO Budget Heather Anderson, Budget Manager, CFO Budget MHBG: Marcie Ochoa-Gamez, Budget Manager, Budget Management

Views of Responsible Officials and Planned Corrective Action: Moving forward the Department will require recipients to provide a list of invoices with the invoice date, period of performance, invoice amount and amount requested/disbursed from ARPA and/or other funding sources to be included with each disbursement request. Staff training will be modified to ensure staff understand allowable expenditures and period of performance restrictions. Anticipated Completion Date: June 30, 2025 Contact Person: Debby Dickson Water Development Division Manager Arkansas Department of Agriculture-Natural Resources Division 1 Natural Resources Drive Little Rock, AR 72205 (501) 225-1598 Debra.Dickson@agriculture.arkansas.gov

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Allowability & Period of Performance Corrective Action Plan: The Agency is in the process of developing a subrecipient monitoring tool to ensure effective controls and processes for uniform oversight of subawards across the program. Additionally, the Agency had not conducted an internal audit of programs supported by American Rescue Plan Act (APRA) funds at the time of this audit. The program is in the process of preparing and completing the audit to assess and strengthen compliance measures and ensure these funds are utilized appropriately. Future audits and reviews will be conducted periodically to ensure ongoing oversight and adherence to regulations. Contact: Nicole Vint Anticipated Completion Date: 6/30/2025

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Period of Performance Corrective Action Plan: The Agency will work with Federal Partners to determine allowability of these claims. Contact: Heather Arnold Anticipated Completion Date: 6/30/2025

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Period of Performance Corrective Action Plan: A validation will be added into the case management system (QE2) that prevents an obligation from being created in a federal fiscal year with a service start date in a previous federal fiscal year. Contact: Cathy Callaway Anticipated Completion Date: April 1, 2025

Management’s Response and Corrective Action Plan: Alpine Achievers Initiative acknowledges the finding and recommendation. Late submissions occurred due to delays on responses from the grantor. Management will be more proactive in documenting communication regarding Period Expense Reports (PERs) to ensure that, if they are submitted late, there is clear evidence of why and what date they were initially submitted. Management is now aware that the PER system only reflects the final submission date once approved, not the initial submission date. To address this, Alpine Achievers Initiative (AAI) will implement a process to document the initial submission date along with any backup documentation of delays, including communications with Serve Colorado or other relevant parties. Additionally, Serve Colorado has clarified that while timely submission of PERs is required, grantees who communicate a need for additional time by the 15th of the month are considered compliant. Serve Colorado also noted that, based on AAI’s history and previous communications, they would not consider this a finding or an indicator of poor performance. Moving forward, AAI will ensure that any anticipated delays are formally communicated to Serve Colorado before the due date and that records of these communications are retained for audit purposes. Contact and Completion Date: Megan Strauss (megan@alpineachievers.org) is the primary contact, and the Executive Director at Alpine Achievers Initiative The correction action is expected to be resolved before the end of the next fiscal year-end of July 31, 2025.

Condition: Costs were charged to the grants for payroll and related benefits earned prior to the start of the grant period. Corrective Action Planned: We had budgeted the full cost of one teacher and four teaching assistances in the IDEA 240 grant for 2024. The approval process for the grant took longer than expected, our intent was always to comply, but we do realize we should have waited for the approval to be in place prior to charging the costs of these employees to the grant. In the future we will wait for the approval process to be complete and will then charge the employees there. Anticipated Completion Date: July 1, 2025 Contact: Martin Anguelov, Chief Financial Officer for Nantucket Public Schools and Deb Gately, Director of Special Education for Nantucket Public Schools

Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Corrective Action Planned: The Sandwich Public Schools will implement the following procedures to ensure that the 120 liquidation finding doesn’t happen again. 1. We will make sure that all costs are liquidated within the 120 day window after the end of the grant period. 2. If we see we are approaching the 120 day limit on a certain expense, we will reach out to DESE to ask for an extension to the 120 day liquidation requirement. 3. We will add these procedures to our Federal Grant Manual so that all are aware of these requirements. Anticipated Completion Date: June 30, 2025 Contact: Michelle Austin, Director of Finance and Business Operations

Condition: There was no evidence of a system of internal control over the cash management requirements, including a written policy related to reimbursement of funds on a per-refugee basis. In addition, it was noted that reimbursement was requested prior to incurring expenses on a per-refugee basis. There were also refugee costs coded incorrectly within the general ledger. Planned Corrective Action: Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that individual refugee costs were coded to the correct general ledger account. Contact person responsible for corrective action: Linda P. Foster, CEO Anticipated Completion Date: Refugee ledger reconciliation process completed 2/1/2025 Policy approval and implementation to be completed by 5/1/2025

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Material Weakness Summary of Finding: There is no administrate review of reimbursable expenses submitted to MAESSU by the district payroll clerks. Lack of an internal control. Contact Person Responsible for Corrective Action: Jami Parks, Business Manager Contact Phone Number and Email Address: 812-794-9630, jami.parks@scsd1.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Clerk will submit the reimbursement requests to the corporation Business Manager for review before the reimbursement is submitted to MAESSU for payment. Anticipated Completion Date: The anticipated completion date will be with the April reimbursement submission.