Corrective Action Plans

In response to finding number 2021-SA5, management agrees with the finding and will design, implement, and maintain policies and procedures that ensure program income is tracked and expended appropriately.

In response to finding number 2021-SA2, management agrees with the finding and will design, implement, and maintain internal controls over all direct and material compliance areas (other than eligibility). Additionally, management will ensure that the Organization’s internal controls comply with the Comptroller General of the United States’s “Standards for Internal Control in the Federal Government” or COSO’s “Internal Control Integrated Framework”.

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

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.

CUAHSI uses a single payment gateway for registration on CUAHSI events, which is the organization’s only source of program income during the audit year (2019) up to present day (February 2024). The CVENT platform segregates events and CUAHSI program staff align these event codes to the grants supporting the events. Though identifiable through the CVENT system, our external contract accounting team failed to record and classify the program income to the correct grant in the accounting books and incorrectly included some grant expense reimbursement revenue in the program income transactions and totals provided to the auditors. Reporting program income to NSF through the annual program income report was not affected and was reported accurately. CUAHSI has addressed this issue by building its financial team and hiring accounting employees (as of September, 2023) with the skills, knowledge, and experience to appropriately manage the finances of federal awards. The new accounting team has applied proper identification of the events and have corrected the misclassification done by the former contractors.

Program income of $293,591 was entered into Sage and submitted to the auditor along with all other General Ledger details. Separately, CUAHSI reported program incomes of different (smaller) amounts to NSF that are likely reflective of actual incomes generated by the active awards. Potential mischaracterization in General Ledger detail may have resulted in overstating program income. The organization is working to implement processes that are 2 CFR Part 200.307 compliant and will be work with their cognizant agency to reconcile accurate program income relative to award draws.

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.

Recommendation: We recommend the City maintain a complete listing of outstanding loans and prepare and regularly use a master CDBG-related loan repayment schedule detailing all loans issued to monitor and capture loan repayments that would prompt the recording of program income as repayments are received. In addition, loans receivable should be reconciled to the general ledger on a regular periodic basis. This addresses COSO's Control Activities, Principle 10: selects & develops control activities and Principle 12: deploys control activities through policies and procedures Management Response and Corrective Action Plan City's Response: The City concurs with the recommendation Corrective Action Plan: The Controller's office will work with the Grants Division to implement tracking procedures, recording procedures and processes, creation of a centralized database that clearly identifies program income including loan repayments and provide training to staff on how to track, record and report program income. This system will be communicated to all staff members within Grants Division, City Controller's Office and Treasury Department to ensure all parties have access to the database, policies and procedures so they are able to properly code each payment in order to monitor the payment type and record the payment in the correct fiscal year. The Grants Division will create a CDBG procedures manual that documents policies and procedures designed to serve as the system of internal controls required by OMB's Uniform Guidance (2 CFR 200). In the meantime, the Grants and City Controller's departments will take steps to address the specific finding noted above. Planned Implementation Date: June 30, 2021 Responsible Person: Aubrey Relf, Grants Manager and Rafaela King, Controller

Recommendation: We recommend the City strengthen their procedures in relation to identifying, determining, assessing, and recording program income. The City should have procedures in place to accurately identify program income when are received and to ensure that program income is appropriately recorded in the CDBG fund as such and into IDIS. This addresses COSO's Control Activities, Principle 10: selects & develops control activities and Information & Communication, Principle 15: communicates externally. Management Response and Corrective Action Plan Corrective Action Plan: The Controller's office will work with the Grants Division to implement tracking procedures, recording procedures and processes, creation of a centralized database that clearly identifies program income including loan repayments and provide training to staff on how to track, record and report program income. This system will be communicated to all staff members within Grants Division, City Controller's Office and Treasury Department to ensure all parties have access to the database, policies and procedures so they are able to properly code each payment in order to monitor the payment type and record the payment in the correct fiscal year. The City will create a procedures manual that documents policies and procedures designed to serve as the system of internal controls required by OMB's Uniform Guidance (2 CFR 200). In the meantime, the Grants and City Controller's departments will take steps to address the specific finding noted above. Planned Implementation Date: June 30, 2021 Responsible Person: Aubrey Relf, Grants Manager and Rafaela King, Controller