Corrective Action Plans

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency has updated its documented controls to require confirmation that agreements are signed by all parties before processing adoption subsidy packets. Adoption staff will be trained on the updated controls. Anticipated Completion Date: 3/31/2024 Contact Person: Name: Tiffany Wright Title: Director, Division of Children and Family Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-396-6477 Email Address: Tiffany.Wright@dhs.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: The agency agrees with the finding. We found an error in the formula of the worksheet used for the preparation and submission of the quarterly expenditure report. The error resulted in not properly reporting the CARES Act reimbursement. The agency will report to the federal Child Support Services program to account for the over-reimbursement of federal share of expenditures. The error in the specific worksheet that resulted in the over-reporting of allowed expenditures has been corrected. Further, the agency will perform a review of all other subsidiary reports and worksheets that are used in preparation of the federal expenditure reports. This will be done in order to ensure that the federal reports are prepared accurately. Additionally, procedures for review of report preparation will be enhanced to further strengthen internal controls. Anticipated Completion Date: Correction of the specific worksheet deficiency has been completed. Corrections to the federal reports to account for the over-reimbursement will be completed in the next federal reporting cycle due on May 15, 2024. Review of all other subsidiary reports and worksheets and the enhanced report preparation review is part of an ongoing project to be completed no later than August 15, 2024. Contact Person: Name: Robert Hallmark Title: Agency Controller II Agency: Department of Finance and Administration-Office of Child Support Enforcement Address: 322 S Main St, Suite 100 City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-6306 Email Address: Robert.hallmark@ocse.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. The ADE Finance unit utilized data extracted from the statewide Local Educational Agencies (LEAs) system, APSCN, for the majority of parameters reported. However, APSCN does not have the ability to cross-reference financial expenses with Local Educational Agency’s (LEAs) personnel data, which led to the creation of the survey. LEAs were expected to report data during a subsequent school year post COVID-19 Pandemic. ADE gathered state total expenses for requested categories from the system compiled with the requested breakdowns by position type obtained in the manual survey. The two data sets did not align, thus seen in Questioned Costs which reflects the difference between the two datasets. LEA actual expenses, associated drawdowns, and disbursements were not affected by the amounts reported in the annual ESSER data. ADE Finance is currently working with APSCN personnel to explore options for assembling data without manual input from LEAs. When implemented, discrepancies in the state data reported to federal systems and LEAs data should not exist. ADE has the goal of utilizing this method for FY23 reporting in May 2024. Anticipated Completion Date: ADE Finance will revise its uploaded FY22 ESSER data template during the allowable period of July 29, 2024, through August 15, 2024. Contact Person: Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. ADE Finance completed the named report which contained a subtotal error that overstated the totals when provided to Legislative Auditors. However, logic verifications built into the Federal System disallowed the items mentioned to be submitted. Therefore, the data reflected in Federal reporting for Arkansas was not overstated nor actual expenses and associated drawdowns completed erroneously. This information was confirmed with the U.S. Department of Education (ED) on February 21, 2024. ADE Finance assures that revisions to the FY23 ESSER data template will be made and uploaded to the Federal Reporting System during the allowable period of July 29, 2024, and August 15, 2024. Anticipated Completion Date: Data was effectively corrected at the time of reporting within the Federal System. ADE Finance will revise its uploaded FY23 ESSER data template during the allowable period of July 29, 2024, through August 15, 2024. Contact Person: Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: ASBO has entered a contract with a new 3rd party administrator to provide oversight for all subgrant awardees. This contact is active now. We developed our contract to ensure improved monitoring for expenditures and verification of receipts. Also, we are in the process of developing a portal which will allow this contractor and ASBO to have full access to all documents from subgrantees. Our new vendor does have prior experience with subgrants management. In addition, ASBO commits internally to the following: • We will monitor all capital purchases when the invoices are received at our office. • We will pull a random sample of five invoices per month and conduct our own review of expenses. Views of Responsible Officials and Planned Corrective Action (Continued): Highlights for the Baker contract: ASBO’s broadband grant program management vendor-partner, Michael Baker International (MBI), is contracted for the following activities and deliverables: • Developing the workflow, process, and online forms that facilitate project monitoring and expense reimbursement. • Responsible for pursuing and documenting additional information required for project monitoring and reimbursement activities. These activities shall be completed within the framework of the Broadband Grants Project Monitoring and Reimbursement System (see below for details) and not through external email or other document exchange system. • Develop and apply standardized naming conventions for all project documents that will be maintained throughout the life of the project. Documents shall be stored in a manner that promotes transparency and facilities ease of use by auditors. • Take all reasonable measures to ensure grant activities are implemented in a manner that ensures transparency, accountability, and oversight sufficient to (1) minimize the opportunity for waste, fraud, and abuse; (2) ensure that subrecipients use funds to further the objectives of Federal programs and the Arkansas State Broadband Office; and (3) allow the public to understand and monitor subgrants awarded under the program. • Ensuring all reimbursement activity complies with Federal requirements, including Section 60102 of the Infrastructure Act, 2 C.F.R. Part 200 and any supplemental guidance issued by the Federal government. • Responsible for knowing what constitutes eligible and ineligible expenses under both state and Federal rules. • Provide education and guidance to subrecipients and the ASBO on key oversight and compliance requirements. • Ensure payment activities follow all state and Federal policies and procedures. Contractor acknowledges policies may change over the life of the contract. • Identify policies the ASBO is required to adopt and assist in drafting those policies to ensure ASBO compliance with Federal regulations. • Assist the Arkansas State Broadband Office in enforcing program rules and laws and imposing penalties for nonperformance, failure to meet statutory obligations, or wasteful, fraudulent, or abusive expenditure of funds. Such penalties include, but are not limited to, imposition of additional award conditions, payment suspension, award suspension, grant termination, de-obligation/clawback of funds, and debarment of organizations and/or personnel. Views of Responsible Officials and Planned Corrective Action (Continued): • Conduct audits of subrecipients as are necessary and appropriate. Contractor shall report the results of any audits it conducts to the Arkansas State Broadband Office. • Develop a template contract for subrecipients, specifying key terms including contract length, performance standards, construction and service rollout schedules, competitive access requirements, regulatory compliance requirements, environmental controls, grant reporting and data sharing requirements, monitoring and oversight procedures, and penalties for non-compliance. • Retain and provide to the Arkansas State Broadband Office upon request all records, documents, and communications of any kind that relates in any manner to grant awards and project procurement, performance, and reimbursement. This data shall be labeled and stored in a manner that promotes transparency and facilitates ease of use by auditors. Additionally, MBI is building two new systems for ASBO and subgrantee use: 1. Broadband Grants Project Monitoring and Reimbursement System 2. Grant Application Submission, Evaluation, Award, and Appeal System These systems will have the following features: • Facilitate inputs, responses, data gathering, analysis, and adjudication decision recommendations and subsequent documentation of payment decisions for the Arkansas State Broadband Office’s final approval. • Provide a secure mechanism for grant applications and safeguard protected, proprietary, and other confidential information. • Assign a unique identifier to each application and each project. Contractor shall develop and apply a standardized naming convention to all applications and associated documents that will be maintained throughout award, technical review, project monitoring, and project closing. Documents shall be named and stored in a manner that facilitates ease of use by auditors. • System shall exhibit built-in quality controls, such as pre-screening, that assist applicants in submitting applications that meet all minimal requirements for consideration (such as requiring a SAM number). • MBI shall be responsible for pursuing and documenting additional information required for clarification of submitted applications, technical reviews of applications, and project monitoring Views of Responsible Officials and Planned Corrective Action (Continued): • and reimbursement activities. These activities shall be completed within the framework of the Grant Application Submission, Evaluation, Award, and Appeal System or the Broadband Grants Project Monitoring and Reimbursement System and not through external email or other document exchange systems. Anticipated Completion Date: System anticipated go live Date: April 26, 2024 Contact Person: Name: Glen Howie Title: Director Agency: Department of Commerce, Arkansas State Broadband Office Address: 1 Commerce Way, Suite 601 City, State, Zip: Little Rock, AR 72202 Phone Number: 501-682-1123 Email Address: Glen.howie@arkansasEDC.com

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the controls the ALA staff recommended. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. Specifically, the documentation provided to auditors during the audit period did not include a full review of allowable expenditures correlated to the federal draws. During the quarter, indirect costs are estimated and are then adjusted to actual indirect costs when the quarterly cost allocation report is completed. If an overpayment was identified after comparing to the cost allocation report, the next federal draw would be reduced by the overpayment. Due to the timing of the DHS Cost Allocation report and the omittance of the allowable 2022 CNP Block grant expenditures, the expenses were understated for 2023 CNP Block grant resulting in the appearance of a federal overpayment. Following the audit, it was determined DHS DCCECE staff coded 161 transactions totaling direct costs of $1,977,927.62 of allowable expenses for October 2022, November 2022, and March 2023 in the State’s accounting software, AASIS, to the 2022 CNP Block grant when only $505,835.54 federal grant funds were available. The difference of $1,472,092.08 in federal funding was properly drawn from the 2023 CNP Block grant, but AASIS error corrections were not timely submitted to the managerial accounting prior to the close of SFY2023 to ensure the proper allocation of the expenditures. The cost allocation report provided to auditors during the audit period only included the 2023 CNP Block grant AASIS coding and did not include the 2022 CNP Block grant AASIS coding of $1,472,092.08. The remaining difference of $24,186.92 is due to timing of DHS’s Cost Allocation quarterly report that became available July 20th for the June 30th 2023 CNP Block grant expenses. DHS submitted additional documentation to ALA in February 2024 accounting for all allowable expenditures. DHS Managerial Accounting staff have been provided additional cost allocation training and audit response training. Documents responsive to audit requests will be more fully reviewed prior to submission as senior finance management staffing allows. Effective August 1, 2023, DHS DCCECE has transitioned to Arkansas Department of Education (ADE). DHS will continue to work in cooperation and coordination to provide all relevant financial information, documentation, or other items necessary for the administrative functions of DCCECE so as not to disrupt any services. Arkansas Department of Education Response Arkansas Department of Education, Finance unit monitors fund balances in the States’s accounting system, AASIS, at minimum, every other day. The frequency of this process accounts for previous activity in funds or cost centers and pending activity recognized at the time of the review including, but not limited to, upcoming expenses and drawdown requests. ADE procedures ensure the finance unit closely oversees cash on hand, if any, and all necessary drawdowns are completed for immediate use. Additionally, funds associated with the Office of Early Childhood (formerly DCCECE) that were carried to ADE are shown in the cash edit table, allowing the fund to have a negative balance in the State’s accounting system, AASIS. Including funds in the cash edit table supports the agency in preventing excess drawdowns by allowing funds to be received after expenses are processed. ADE is confident this procedure ensures accurate amounts are drawn. Anticipated Completion Date: Department of Human Services Response Complete Arkansas Department of Education Response ADE Finance has implemented the named procedure and continues to monitor cash on hand closely, as the ADE Office of Early Childhood staff, (formerly DHS DCCECE), are trained in this procedure. Contact Person: Name: Misty Eubanks Title: Deputy Secretary for Operations and Budget and Interim Chief Financial Officer Agency: Department of Human Services Address: P.O. Box 1437, Slot S201 City, State, Zip: Little Rock, AR, 72203-1437 Phone Number: 501-320-6327 Email Address: misty.eubanks@dhs.arkansas.gov Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. The Division of Childcare and Early Childhood Education (DCCECE) utilized a custom software platform to provide payment files to the State’s accounting software, AASIS, to issue payments to recipients. Within this software, the AASIS coding for Sponsor Administrative costs is coded to CNP Block Consolidated (ALN 10.555) instead of CNP CACFP Sponsor Administrative (ALN 10.558) for the questioned costs of $98,474.00. Expense error corrections were not received timely by managerial accounting staff prior to the close out of SFY2023. Effective August 1, 2023, the division formerly known as DCCECE at DHS transitioned to the Arkansas Department of Education (ADE). DHS alerted financial staff with ADE in February 2024 to review the custom software platform to ensure grant expenses are being properly coded now. Due to depleted grant funds in CNP CACFP Cash in Lieu (ALN 10.558), the questioned costs of $38,341.68 in grants funds were manually moved by DHS Managerial Accounting staff into the CNP Block Consolidated grant. Managerial accounting staff have been retrained to ensure adequate federal funds are available prior to drawing. If manual adjustments are required, the division’s CFO, or their designee, must review and approve manual adjustments prior to the managerial accounting staff executing manual adjustments. DHS Office of Finance is developing an internal control documenting the prior approval process. DHS will continue to work in cooperation and coordination with ADE to provide all relevant financial information, documentation, or other items necessary for the administrative functions of DCCECE so as not to disrupt any services. Arkansas Department of Education Response The Arkansas Department of Education, Finance unit monitors federal grant awards by using separate cost centers for each program and award year within. This process provides transparent delineation of expenses and revenues within the State’s accounting system, AASIS. Additionally, ADE Finance owns an established procedure to reconcile federal grant awards for each month, within 90 days of the month’s end. The reconciliation procedure accounts for all activity within the grants and ensures data is aligned from the federal drawdown system to the State’s accounting system, AASIS. Anticipated Completion Date: Department of Human Services Response 3/31/2024 Arkansas Department of Education Response The itemized CNP programs are reconciled using ADE procedures as of August 1,2023. ADE ensures the accuracy of data from August 1, 2023, through January 31, 2024. Contact Person: Name: Misty Eubanks Title: Deputy Secretary for Operations and Budget and Interim Chief Financial Officer Agency: Department of Human Services Address: P.O. Box 1437, Slot S201 City, State, Zip: Little Rock, AR, 72203-1437 Phone Number: 501-320-6327 Email Address: misty.eubanks@dhs.arkansas.gov Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

Corrective action planned: Utilize a CPA experienced with federal award to review and ensure compliance with grant proposals and activities. Anticipated completion date: April 30, 2024 Contact person responsible for corrective action: Jalen Tollefson, Grant Director

Finding 2023-001 – Head Start Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all vouchers are reviewed by a secondary individual, all supporting backup is maintained for each claim, and all payroll amounts agree to approved contracts. Anticipated Completion Date: April 2024

Finding No. 2023-02: Cash Management During the year, a condition was noted that $87,640 of federal funds were drawn and were not expended in a timely manner. Management recognizes the important of complying with federal reporting guidelines and repaid the federal funds on September 1, 2023. In addition, as a response to finding 2023-02, efforts will be made to ensure that federal funds are only drawn to reimburse the Organization for eligible expenses previously incurred. If funds must be drawn in advance, management will establish policies and procedures that are consistent with the Uniform Guidance administrative requirements to ensure the funds are expended in a timely manner.

Finding No. 2023-01: Allowable Costs (Time and Effort) In finding 2023-01, a condition was noted that salaries and wages charged to the Opioid STR (ALN 93.788) federal award were based on preliminary time and effort estimates. Employees and clinical staff track their time by the grant/program but actual time was not reconciled to the preliminary time and effort estimates before billed. As a response, the Organization updated its timekeeping system to include pay codes to allow every employee to input their actual time and effort for each specific grant. The timecards will be completed by each employee and reviewed by their supervisor. This updated timekeeping system will ensure salaries and wages charged to federal grants is based on actual time and effort. The updated timekeeping system was implemented in December 2023.

Condition - The District's expenditure report filed for June 30, 2023 included expenditures that were not disbursed as of June 30, 2023. These amounts were not reported as committed or obligated and were not liquidated within 90 days of the end of the fiscal year. Plan - Management will monitor expenditure reports to ensure that amounts claimed have been disbursed prior to submitting the report or included them as obligated. Anticipated Date of Completion - June 30, 2024. Management Response - There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed or obligated expenditures will be reported appropriately, and will be liquidated within 90 days of the end of the fiscal year.

Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Marymount University experienced high turnover in the Office of Financial Aid from the Director down to the counselor position in the 22-23 academic year. In that transition, Attain partners was contracted in late 2022 as interim staffing. For the one student in the finding that was found to have received a grade level 3 loan instead of level 2 based on the number of credits completed, research found that a rule setting in Ellucian Colleague caused the student to be auto-packaged at level 3 and it was accepted and disbursed in COD (Common Origination & Disbursement). Moving forward, Attain Partners will work with Marymount IT to update any rule settings to catch this issue and provide the Marymount Financial Aid office with internal controls that will catch any issues for the current aid year. Management notes that this issue arose due to a software programming error tied to an updated rule setting in Ellucian Colleague. Moving forward staff in Financial Aid will work in tandem with colleagues in Information Technology to review all updated rule setting in order to catch and address potential miscalculations. Name(s) of the contact person(s) responsible for corrective action: Meghan Sutton, Interim Director of Financial Aid, 703.284.1532 Planned completion date for corrective action plan: May 2024

Recommendation: We recommend the District design procedures and controls to ensure adequate prior approval of construction related expenditures charged to the Education Stabilization Fund program. Explanation of disagreement with audit findings: There isno disagreement with the audit finding. District Response: Name of the contact person responsible for corrective action: Ruben Hernandez, Assistant Superintendent, Business Services. Planned completion date for corrective action plan: Immediate.

Condition: The Commission was unable to provide adequate source documentation to support that the match requirement was met. Planned Corrective Action: Management agrees that match requirements for Continuum of Care awards have not been maintained as required by the Uniform Guidance. In July 2023, management was notified by HUD after completion of an on-site monitoring visit that the Commission's claimed matching expenses that were not adequately supported by source documentation. In response, management has placed in service additional controls to ensure the compliance requirements are being monitored and in place for the new program. Contact person responsible for corrective action: Steve Raiche Anticipated Completion Date: 6/30/2024

Please find below the corrective action plans for Klamath Falls City School’s audit for the period ending June 30, 2023. Finding: Excess indirect costs of $70,531 were requested and received. Department’s Response: Cause: The excess was primarily due to a period of transition of business staff. This created a duplicated claim for 2 quarters for a majority of the amount identified. After the transition of department personnel, the corrective action to assure that this issue does not happen again is to submit claims monthly and claim indirect costs at that time. At the end of each quarter review each account and reconcile expenses to claimed indirect costs to assure we are 100% in compliance. Name of Responsible Person: Charity Roach, Business Manager Name of Department Contact: Charity Roach, Business Manager Projected Implementation Date: Implemented

Action taken in response to finding: As referenced in the Audit report, a comprehensive new Procurement procedure that is fully compliant with Uniform Guidance was implemented in April 2023 and has been in place and utilized since then. In addition, a preferred Vendor list will be generated by May 31st, 2024. This list will also be reviewed and updated at least on an annual basis, with interim revisions being done as needed. Name(s) of the contact person(s) responsible for corrective action: Matt Gehri, CFO Planned completion date for corrective action plan: April 2023 for new Procurement procedure, and May 31st, 2024 for Preferred Vendor list.

Action taken in response to finding: A comprehensive spreadsheet including all wages allocated to Federal Grants was created during the course of the Federal Awards program Audits. This spreadsheet allows SBCHC staff to track and verify all wages allocated to Federal Awards on a contemporary basis with internal checks and balances included. These verification processes now happen with every payroll cycle and are documented as such. Any revisions that are required now occur on a regular basis and correspond with the bi-weekly payroll cycle. Name(s) of the contact person(s) responsible for corrective action: Matt Gehri, CFO Planned completion date for corrective action plan: Currently deployed as of February 2024, and has been reviewed back to the beginning of the H80 Federal Grant year of May 1, 2023.

Views of Responsible Officials: Grant funds received pursuant to a period of performance or an approved drawdown or reimbursement request will be expended as specified in the request. When Federal grants are funded in advance, rather than on a reimbursement basis, the Foundation will minimize the time elapsing between the receipt of Federal grant funds and disbursement of such funds for their approved purpose. We will implement procedures to ensure that expenses are recorded or accrued properly.

The City will implement policies and procedures to ensure the City itself is not identified as a subrecipient and that all City payroll charges are supported by timesheets and other supporting documentation required by the Uniform Guidance. The City staff have been trained regarding these policies and procedures and the proper coding of their timesheets to support payroll charges.

The County is aware of the above finding and has adjusted our procedures related to disbursing federal funds to subrecipients. We have changed to a cost reimbursement basis for disbursing the federal funds to subrecipients. We currently receive supporting documentation prior to payment.

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended June 30, 2023. Finding 2023-001 Responsible Party Name: Amy Spaeth Position: Co-CEO – Management Agent Telephone Number: 816-236-2435 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities (Section 811) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We have deposited the shortfall of $4,320 into the reserve for replacement account in July 2023. We will follow our process to deposit and reconcile the reserve for replacement account on a monthly basis. Anticipated Completion Date N/A

Internal control procedures will be strengthened between Financial Aid, the Registrar’s Office, and the Bursar’s Office.

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.278 WIOA Dislocated Worker Formula Grants Contact Person: Jeremy Flowers, WIOA Executive Director Anticipated completion date: June 30, 2024 Concur. To help ensure the County meets the WIOA Cluster’s earmarking requirement to spend no less than 20 percent of WIOA Youth Activities funds allocated to the County to provide in-school and out-of-school youth with paid and unpaid work experiences (WEX), the County has revised its process for tracking work experience expenditures. The County will utilize the revised process and provide technical assistance to the sub-recipient, Chicanos Por La Causa (CPLC) to implement procedures that will lead to an increase in Youth enrollments and placement into WEX to ensure at least 20 percent of the WIOA Youth Activities funds allocated to the County are used to provide in-school and out-of-school youth with paid and unpaid WEX. County staff are currently working with CPLC staff to implement a different approach to attaining the WEX requirements. The recommended solutions include improved tracking and monitoring of the WIOA Youth WEX activities to include both paid and unpaid work experiences, increasing all youth outreach, partnering with other local youth programs, and enrolling youth with barriers pursuant to current policy. The County will be tracking Youth progress and will be revising strategies as needed. The County’s goal is to see a significant increase in Youth WEX program activities by the end of fiscal year 23-24.