Corrective Action Plans

Finding 2022-004 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: The Period of Availability for the SPED PL 94-142 Grant was September 29, 2021 through September 30, 2023. Condition: During our test of controls over compliance it was noted that there are expenditures charged to the SPED PL 94-142 Grant (September 29, 2021 through September 30, 2023) for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Context: During our test of expenditures and review of the general ledger against the SPED PL 94-142 Grant as it is related to compliance it was noted that the first payroll charged to the grant were for services prior to the grant start date of September 29, 2021 and thus would be outside the period of performance and thus would not be allowable costs. Effect: The School Department was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned costs for the first payroll charged to the grant whose service period was prior to the grant start date of September 29, 2021 was $7,249.98. Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing. Recommendation: We recommend the School Department follow procedures to ensure that expenditures charged to the grant are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Managements Response: Management agrees with the auditors’ findings and will put in procedures and policies to correct the action going forward. Responsible for Corrective Plan: Patrick McIntyre, School Business Manager Estimated Completion Date: Fiscal Year 2023 Action Taken: The School Department ensures that expenditures charged to the grant only once approved and within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education (DESE). Accounting codes are not set up for individual grants until final approval from DESE.

Finding 2022-001 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Town is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context: Control deficiencies related to disbursements were noted as a result of the testing of internal controls over payroll. Specifically, a sample of payroll disbursements charged to the programs were tested in order to determine if adequate internal controls were in place. As a result of the testing of payroll disbursements charged to the programs, all of the employees tested were found to not have adequately approved employee payroll rate agreements. Cause: Weaknesses in the design and operation of controls. Effect or Potential Effect: Due to the weaknesses in internal controls noted above, there is a risk of inappropriate salaries and wages being paid. Identification as a Repeat Finding: Yes, finding number 2021-001 Questioned Costs: Questioned costs are reported equal to $256,796.58, calculated as payroll charged to the programs. Recommendation: The Town should improve internal controls over Activities Allowed/Allowable Costs by ensuring employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner. Managements Response: Though we believe that Finding 2022-001occured due to staff turnover at the time of the rate agreement approval, the Town and the Schools will assure federal awards are expended only for allowable activities. Consistent with State and Federal requirements and as in Acushnet’s updated Federal Grant Procedures Manual (February 2023), the Town will maintain source documentation (invoices, time sheets, payroll stubs, etc.) – including approved payroll rate agreements – that support federal expenditures. Responsible for Corrective Plan: Patrick McIntyre, School Business Manager Estimated Completion Date: Fiscal Year 2023 Action Taken: All employee’s payroll rate agreements are approved by an appropriate level of management and in a timely manner.

2022-006 – Allowable Costs Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Immunization Cooperation Agreements Assistance Listing Number: 93.268 Federal Award Identification Number and Year: FY 21/22 and 22/23 Pass-Through Agency: Pennsylvania Department of Health Pass-Through Number(s): None Award Period: 1/1/2022 – 12/31/22 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Condition and Context: While testing allowable costs relating to payroll expenditures, sixteen out of forty transactions were identified that could not be appropriately re-calculated per the amount that was charged to the grant. The County was not able to provide support for payroll expenditure amounts charged to the grant for part-time hourly employees. Recommendation: We recommend management should review the process of timekeeping for grant eligible employees for daily time input, as well as grant authorized wages. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grant Accountant met with department staff to review the time tracking process for grant-eligible employees to ensure that all payroll expenditures charged to the grant are eligible, authorized, and charged on an individual employee basis. Project codes in Infor allow salary distribution and personnel information to be assigned to each grant. Where possible, this function is to assist in supporting the amounts charged to the grant program. The department will maintain documentation to support the amounts and allowability of the charges applied to the grant for payroll. The County is evaluating new time tracking systems to be implemented in 2025 that will allow for time tracking and reporting at a grant/program level. Name(s) of the contact person(s) responsible for corrective action: Thomas Landauer and Dean Dortone Planned completion date for corrective action plan: March 2025

Finding #SA2022-006 Compliance with Grant Documentation Requirements Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Pass Through Entity: California State Water Resources Control Board Federal Award Identification Number: 68-0281986 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City will develop procedures to ensure all documentation is provided • Anticipated Completion Date: 06/30/24

Finding #SA2022-008: Accurate Review and Payment of Vendor Reimbursement Requests Assistance Listing Number: 14.218 Assistance Listing Title: COVID-19 - Community Development Block Grants/Entitlement Grants Name of Federal Agency: Department of Housing and Urban Development Pass Through Entity: San Joaquin County Community Development Department Federal Award Identification Number: A-93-916 • Name(s) of the contact person: Shay Narayan, Director of Finance; Carmen Gusman, Deputy Director of Finance • Corrective Action Plan: The City will develop procedures to ensure accurate review and payment of vendor reimbursement requests, including providing training to administrative staff as necessary. • Anticipated Completion Date: 06/30/24

TINDLEY ACTION PLAN 1. Develop and implement Procurement Policy (completed and on-going by CFO/Accounting Manager/Accountant/Grants Manager/Network President/Department Heads) a. Enhance written procedures for procurement and accounts payable. i. Purchases between $15,000-$25,000 will require two quotes for all new vendors; purchases between $25,000-$75,000 will require three quotes for all vendors; and purchases over $75,000 will require a competitive bid process for all vendors. ii. Establish a Master Vendor list. 1. Master Vendors may be used for up to $20,000 for regular services and products in the normal course of business with dual approval by the Network President and CFO. b. Require vendor bids/quotes for services. c. Segregate purchasing duties. 2. Research new vendors prior to utilization (implemented and ongoing by CFO/Accountant) a. Are these vendors commonly known in the industry or the community? b. Does the vendor have a valid website, phone number, address and email address? 3. Conduct Periodic/Continuous Fraud-Detection Monitoring (CFO – at every fiscal year end) a. Annually identify (1) Tindley’s top 20 vendors, (2) all Tindley vendors receiving annual payments totaling more than $10,000, and (3) any new vendors receiving annual payments totaling more than $5,000. i. Ensure there are valid and updated contracts for these vendors. ii. Ensure the description for services on the corresponding. invoices are detailed and complete. iii. Assess multiple corresponding invoices that have the same total amounts. 4. Refine and codify job descriptions/job duties for Network President, CFO, Grants & Compliance Manager, and Director of Development (HR/Board to be completed by 9/30/24) a. Keep these job descriptions in a database to ensure a smooth transition in the event of a departure or retirement. b. The job descriptions should highlight the financial compliance aspects of each position. 5. Change reporting structure for CFO (to be implemented by HR/Board 9/30/24) a. CFO will report directly to the Board with a dotted line to the Network President. 6. Provide anti-fraud training for Network President, CFO, Director of Development, Grants & Compliance Manager, and in-house accounting professionals (to be implemented by Network President/CFO and completed by 11/30/24) 7. Establish a Whistleblower/Ethics hotline to report suspected fraud (to be implemented by HR 9/30/24) a. Ensure employees understand that it is available to report suspected fraud. b. Develop procedures for responding to whistleblower allegations. PROCUREMENT POLICIES AND PROCEDURES I. INTRODUCTION AND PURPOSE Tindley should adhere to strict ethical and legal standards to prevent fraud and ensure accountability. This procurement policy should be cross-referenced with current local, state, and federal laws. II. CODE OF CONDUCT A. Conflict of Interest Tindley purchasers shall not participate in the selection, award, or administration of a contract if they have a real or apparent conflict of interest. Such a conflict arises when the Tindley purchaser; any immediate family member (spouse, child, parent, parent in law, sibling, or sibling in law); partner; or an organization that employs, or is about to employ, any of the above has a direct or indirect financial or other interest in, or will receive a tangible personal benefit from, a firm or individual considered for the contract award. An “organizational conflict of interest” is created because of a relationship that a Tindley employee has with a parent, affiliate, or subsidiary organization that is involved in the transaction such that the Tindley employee is or appears to be unable to be impartial in conducting a procurement action involving the related organization. B. Gifts, Money, Gratuities Tindley employees involved in the purchasing process shall not solicit or accept gifts, money, gratuities, favors, or anything of monetary value, except unsolicited items or services of nominal value from vendors, prospective vendors, parties to subcontracts, or any other person or entity that receives, or may receive compensation for providing goods or performing services to Tindley. All Tindley purchasers shall review and comply with Tindley’s procedures for disclosing, reviewing, and addressing actual and potential conflicts of interest. III. PROCUREMENT PROCEDURES A. Procurement Procedure See chart at the end of document B. Bid Procedures All procurement shall be conducted in a manner that provides, to the maximum extent practical, a full and open competition. Tindley bid procedures should always follow local, state, and federal requirements. Procurement Processes should include the following: 1. Assemble a Procurement Committee consisting of the Network President, CFO, Grant Manager, and the requestor of the product or service. i. In the event that the requestor of the product or service is the Network President, a Tindley Board member of the applicable committee that corresponds to the request will be asked to participate. 2. Pre-Bid Phase. i. If an outside vendor is needed to develop the bid specifications for a bid project, the vendor, or related parties to the vendor cannot participate in the bid. ii. The procurement committee should have specific criteria of the bid specifications including how bids will be judged based on price, quality, experience of vendors, etc. iii. All solicitations shall incorporate a clear and accurate description of the technical requirements for products or services to be procured. iv. Identify all requirements which offerors must fulfill and all other factors to be used in evaluating bids and proposals. v. If required by local, state, and or federal laws, Tindley should publicly announce in advance of projects that require a competitive bid process. vi. Vendors should not be allowed to interface with Tindley procurement committee members before any public bids are announced, and post-bid announcement, interactions should occur only as part of the formal bid process (questions and answers in writing, face-to-face walk-throughs, proposal phases, and actual bid submissions). 3. Bid Phase. i. All bidders should have adequate time to respond to a bid, including Q&A sessions, and a face-to-face walk-through if necessary. ii. The Tindley employee sending out bid packages including specifications, should not be the same person receiving the vendor bid submissions. iii. The Tindley employee receiving the bid submissions should time and date stamp each bid received and the committee should exclude any bids submitted after the bid deadline. iv. Tindley employees are forbidden to disclose to vendors information about other bidders, including bid proposal contents such as pricing. 4. Bid Selection Phase. i. The procurement committee should develop a bid template and checklist that ranks bids based on criteria developed by the committee and ensures bid procedures are followed. ii. If the procurement committee chooses the winning bid on criteria other than what is stated in the original specifications, the committee must document the reasons why. For example, if the winning bid was not the lowest price, the committee must justify in writing why the vendor was selected. C. Competition All procurement shall be conducted in a manner that provides, to the maximum extent practical, a full and open competition. 1. Procurements shall avoid noncompetitive practices that may restrict or eliminate competition, including but not limited to: a. Unreasonable qualification requirements. b. Unnecessary experience and excessive bonding requirements. c. Non-competitive pricing practices between firms or affiliated companies. d. Non-competitive contracts to consultants on retainer contracts e. Organizational conflicts of interest. f. Specifying “brand name” only instead of allowing “an equal to product.” 2. Procurements shall not intentionally split a single purchase into two or more separate purchases to avoid dollar thresholds that require more formal procurement methods. 3. Procurements shall include in any pre-qualified list an adequate number of current qualified vendors firms or products. 4. Procurements shall not preclude potential bidders from qualifying during the solicitation period. 5. Procurements shall not use any geographic preferences (state local or tribal) in the evaluation of bid proposals except where expressly mandated or encouraged by applicable federal statutes. 6. The procurement team must find, when possible, bidders to compete that were not provided by the Tindley requester. 7. The procurement committee must use independent judgment and notify the Board of Directors and ethics hotline if the requester of products or services is attempting to use undue influence for the team to select specific vendors. D. Considerations Tindley purchasers should take the following actions when procuring goods and services. 1. Conduct a lease versus purchase analysis when appropriate, including for property and large equipment. 2. Consolidate or break out procurements to obtain a more economical purchase if possible. 3. Use state and local intergovernmental or inter-entity agreements, or common or shared goods and services, where appropriate. 4. Use federal excess and surplus property in lieu of purchasing new equipment and property if it is feasible and reduces project costs. 5. Use time and materials contracts only if no other contract is suitable and the contract includes a ceiling price that the contractor exceeds at their own risk. If such a contract is negotiated and awarded, Tindley must assert a high degree of oversight to obtain reasonable assurance that the contractor is using efficient methods and effective cost controls. IV. PROCUREMENT METHODS A. All procurements made under this policy shall: 1. Be necessary, at a reasonable cost, documented, not prohibited by law or the applicable funding source, and made in accordance with this policy. 2. Avoid acquiring unnecessary or duplicative items. 3. Engage responsible vendors who possess the ability to perform successfully under the terms and conditions of a proposed procurement. 4. Tindley purchasers shall consider vendor integrity, public policy compliance, past performance record, and financial and technical resources. B. Procurement Parameters For all transactions, Tindley shall follow the applicable procurement method set forth in Appendix 1 C. Exceptions to Standards Methods Solicitation of a proposal from a single source may only be used if the following apply and are documented: 1. The item is only available from single source. 2. Public exigency or emergency will not permit any delay. 3. The Federal awarding agency or pass-through expressly authorizes the sole source in response to a Tindley request. 4. After soliciting a number of sources, competition is determined inadequate. V. DOCUMENTATION A. Records Tindley shall maintain records sufficient to detail the history of each procurement transaction. These records must include, but are not limited to: 1. A description and supporting documentation showing the rationale for the procurement method (e.g., cost estimates). 2. Selection of contract type. 3. Written price or rate quotations (such as catalog price, online price, e-mail or written quote), if applicable. 4. Copies of advertisements, requests for proposals, bid sheets or bid proposal packets. 5. Reasons for vendor selection or rejection, including Finance Committee and Board Minutes, rejection letters, and award letters. 6. And the basis for the contract price. VI. COMPLIANCE WITH THIS POLICY Program directors and, where applicable, the purchasing committee, shall maintain oversight to ensure that contractors and vendors perform in accordance with the terms, conditions, and specifications of contracts or purchase orders. Violations of this policy may result in disciplinary action, up to and including termination. VII. VENDOR SELECTION CRITERIA For vendors that have been selected in a competitive bid or that will provide critical services to the school, Tindley should evaluate them based on cost, quality, past performance, experience, and financial stability. Before providing services or products, the selected vendor can be asked to provide references, allow for background checks, and provide documentation such as certificate of insurance, certificate standing, adherence to anti-fraud policies, and contracts with right-toaudit clauses.

Responsible Individual: Ambrosia Ermenc, Business Manager Corrective Action Plan: The district will create requirement within policy and internal controls for time allocation / time logs to be utilized for every staff member salaried out of federal funds. Anticipated Completion Date: ongoing

Responsible Individual: Ambrosia Ermenc, Business Manager Corrective Action Plan: The district will create / implement requirements within policy and internal controls for time allocation / time logs to be utilized for every staff member salaried out of federal funds. Anticipated Completion Date: ongoing

While discussing this issue with the USDA over email it was agreed that other expenses that were previously paid by the district and not covered by the USDA loan would be acceptable to use instead of the miscalculated, overage of the interest expense. The district had spent several hundred thousand dollars in funds above the originally budgeted district contribution towards the Water Storage Tank Project previous to acquiring the loan with the USDA.

The Organization has taken steps to ensure that the calculation of indirect costs is executed properly and reviewed for compliance in accordance with the contract agreement. Management brought the error in the contracted indirect rate to the funders attention initially, but unfortunately a misstep back to the original contract terms was made before close-out. The development and application of indirect rates will be conducted by the Sr. Director of Finance with oversight by the Chief Financial & Operating Officer and is in place as of the date of this corrective action plan.

Management acknowledges that it is necessary to more specifically itemize employee time that is applicable to the federal grants and contracts that partially fund broad programs and services and has instituted infrastructure to ensure that this is done and documented correctly in the future. The necessary codes are in place in our payroll system and guidance and leadership of the timesheet process will be provided by all program executives (EVP, VP) to all staff that are impacted, with oversight by the Chief Financial & Operating Officer and Sr. Director of Finance. This is in place as of the date of this corrective action plan.

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from four (4) vendors - CJAWS, Inc., Edmentum, Inc., Savvas Learning Company, and Technology Resource Advisors, Inc. This is a repeat finding (2021-007) from the previous fiscal year for CJAWS, Inc. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that the School District update their policies to include those most recent related to ‘federal fiscal compliance’ in accordance with the Uniform Guidance, in particular, procurement policies to address the requirements of Section 2 CFR 200.318(i) and 320(c). In addition, I would recommend that District personnel responsible for expenditures related to federal funding receive updated training related to ‘procurement’ policies and procedures as they relate to federal funding. MANAGEMENT’S PLANNED CORRECTIVE ACTION: Management of the School District will review and update as necessary its ‘federal fiscal compliance policies’ to comply with the requirements of the Uniform Guidance. Particularly as it relates to procurement procedures, for acquisitions of property or services in which the aggregate dollar amount is greater than the micro-purchase threshold but does not exceed the simplified acquisition threshold, the District will obtain and document price or rate quotations from at least three qualified sources. In addition, management of the District will obtain training where available and applicable to enhance their internal controls over the management of federal program funds. The District’s timeframe for implementation is effective immediately.

CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not perform debarment and suspension checks for contractors through SAM.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the District is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. RECOMMENDATION: I am recommending that the management of the School District utilize the SAM.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. MANAGEMENT’S CORRECTIVE ACTION PLAN: Effective immediately, management will implement the practice of properly vetting future third-party contractors for debarment and suspension in federal assistance programs by utilizing the SAM.gov website, to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance and Executive Orders 12549 and 12689, 2 CFR part 180.

CONDITION: In connection with the Cambria Heights School District’s RTU Replacement Project, the District did not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms were used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the School District will review and update as necessary its ‘federal fiscal compliance policies’ to comply with the requirements of the Uniform Guidance. As a matter of policy, the District will implement the six (6) recommended affirmative action steps to ensure compliance with Section 2 CFR 200.321(a) of the Uniform Guidance. The timeframe for implementation of the updated policy will occur during the first six-months of the District’s 2024-2025 fiscal year, and the practice of applying the affirmative action steps will be effective immediately.

The administration will review the procurement policy in the next management meeting. Division Directors will review the procurement policy with all Program Directors and Managers. Also, see actions for 2022-017

Invoices that are received will be scanned to “invoices”. This will direct them to our electronic software, Docuware. The item will then be forwarded to the appropriate Program Director for approval, and they will indicate the appropriate cost centers / allocations. Bookers will then review the approved coding and entered fiscal software. If there is a question or concern about approved coding by the bookkeeper they will speak with Director of Finance, Ethan Terrio. Once invoices are entered into fiscal software, checks will be printed. The check stub and invoice will be attached to each other and filed in the fiscal department. Paper documents will continue to be maintained in fiscal until we go 100% paperless, then all documents will be stored in Docuware.

All SEFA grants will be tracked thoroughly in FundEZ and annotated with their own cost center code to allow tracking them to be easier. The Director of Finance, Ethan Terrio, will reconcile these awards and expenses once a month to ensure that the numbers tie out in the general ledger. Should there be any issues, he will contact the respective Division Director, either Susan Cody or Roxane Carpenter, to determine the cause of the variance, and how to correct the entry to be accurate.

Finding 2022-003 – Reporting U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)- ALN 21.027 Reporting – Missoula County has implemented a dual control process over CSLFRF reporting. As part of the month end process the accountant in finance will review all expenditures related to obligated ARPA programs and reconcile this activity with each department. At the end of the quarter after all months have closed and prior to Treasury reporting an additional review of quarter will occur by the Senior Accountant in finance. This documentation will be reconciled to the Treasury quarterly reports to ensure accurate reporting. Contact Person Responsible for the Corrective Action: Michelle Denman, Deputy Financial Services Director Anticipated Completion Date of the Corrective Action: June 30, 2023

Finding 2022-004 – Subrecipient Monitoring – U.S. Department of Homeland Security Montana Department of Disaster and Emergency Services BRIC: Building Resilient Infrastructure and Communities – ALN 97.047 The county has established a Core grants team consisting of members of Finance, Auditors Office, and our Grants Department. This team will work closely with all county grant managers. Specifically looking at sub recipient awards, the Core Grants Team will implement the following; Review and update polices related to subrecipient grant management. Polices will be updated to clearly outline roles and responsibilities, and expectations concerning monitoring of Subrecipient grant awards. Develop and implement a training program for all grant managers and staff involved with subrecipient grants. Follow up to ensure staff understand their roles with monitoring subrecipient activities and compliance with terms of the grant. Establish a monitoring framework to include regular checkpoints and reporting mechanisms. Implement standardized reporting for monitoring activities. Implement regular reviews of subrecipient financial reports and compliance documentation. Clearly communicate expectations as often as possible and encourage open communication. Contact Person Responsible for the Corrective Action: David Wall, County Auditor Anticipated Completion Date of the Corrective Action: June 30, 2024

2022-007 – PROCUREMENT AND SUSPENSION AND DEBARMENT Material Weakness/Material Noncompliance Auditee’s Response and Planned Corrective Action The Authority hired a new Executive Director in November 2023. Under new management, the Executive Director will handle all procurements of vendors until a modernization coordinator is hired. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Kayla Potter, Executive Director

2022-010 Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend management review the record-keeping practices to ensure that personnel documentation related to employee pay rates can be easily accessed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken or planned in response to finding: In 2024 the Authority converted to the Kronos Pro payroll system, and is utilizing the software to its fullest capacity. This conversion will ensure that personnel documentation related to employee pay rates can be easily accessed and is audit-ready. The OFM shall include quality monitoring in its updated policies and procedures. The OAC shall oversee the quality monitoring process quarterly. Name of the contact person responsible for corrective action: Heather Mueller Planned completion date for corrective action plan: 9/30/2024.

Federal Program Education Stabilization Fund - Passed through the Pennsylvania Department of Education COVID-19 - Governor's Emergency Education Relief Fund ALN 84.425C; Contract #252-20-0141; Grant Period 03/13/20 - 09/30/22 COVID-19 - Elementary and Secondary School Emergency Relief Fund (ESSER II) ALN 84.425D; Contract #200- 21-0141; Grant Period 03/13/20 - 09/30/23 COVID-19 - ARP ESSER ALN 84.425U; Contract #223-21-0141; Grant Period 03/13/20 - 09/30/24 COVID-19 - ARP ESSER After School Set Aside ALN 84.425U; Contract #225-21-0141; Grant Period 03/13/20 - 09/30/24 Criteria In accordance with Uniform Guidance cost principles, the District is not allowed to charge costs to a grant that are reimbursed by another funding source. Condition The District charged over 100% of the employer paid retirement costs to the grants. The Pennsylvania Department of Education (PDE) reimburses the District approximately 55% of the retirement costs annually. As a result, the District is only permitted to charge the unreimbursed 45% of retirement costs to the grants. Cause The District did not have the review procedures in place to identify the errors in journal entries or to monitor that only 45% of the retirement costs were allowed to be charged to the grants. Effect Unallowable costs were charged to the grants. Questioned Costs ALN 84.425C; Contract #252-20-0141 - $2,373 ALN 84.425D; Contract #200-21-0141 - $78,902 ALN 84.425U; Contract #223-21-0141- $44,757 ALN 84.425U; Contract #225-21-0141 - $250 Context Total retirement costs associated with the salaries charged to the grants was $206,218. Of this amount approximately 55% was reimbursed by PDE, leaving $92,798 allowed to be charged to the grants. The District charged a total of $219,080 retirement expense to the grants, resulting in $126,282 unallowable costs charged to the grants. Repeat Finding No. Recommendation We recommend the District identify all funding streams and have a process in place to ensure that allowable costs are only charged to one funding stream. We also recommend a procedure to be put in place to have a person independent of report preparation review cost reports and underlying expenditures. Management Response Exeter Township School District had turnover in their business office including the Assistant Business Manager, Payroll Clerk, and Accountant positions during FY22 and first part of FY23. All of these positions have been replaced with new hires and training has been provided to all, as well as creating backups for all of these positions. The new assistant Business Manager is undergoing training in grant management, allowable costs, funding streams and report preparation. The Business Administrator will review all cost reports including detailed backup before the report is submitted to make sure only allowable costs are submitted. Exeter Township has additional allowable expenditures that can be charged to the grants to replace the unallowed costs. These expenditures were within the grant period and can be reclassified for contracts: 252-20-0141 and 200-21-0141. For contracts 223-21-0141 and 225-21-0141 the grant period is still in process and the unallowed costs will be replaced with allowed costs.

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN March 11, 2024 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings for the year ended December 31, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - Financial Statement Audit and Federal Award Program Audits Finding 2022-006 - U.S. Department of Housing and Urban Development, Mortgage Insurance Rental and Cooperative Housing for Moderate Income Families and Elderly, Market Interest Rate (Sections 221d(3) and (4) Multifamily - Market Rate Housing), CFDA #14.135 Recommendation: We recommend that management refund any reserve for replacements withdrawals that are not expended for the HUD approved purpose. Action Taken: We agree with Finding 2022-006 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will monitor HUD approved reserve for replacements withdrawals and that they are expended for approved items. If HUD has questions regarding this corrective action plan, please call (803) 873-2377. Sincerely yours, Dwayne Legrant President Omni Property Management and Development Managing Agent

Mount Sinai Foundation, Incorporated 703 Blue Street Fayetteville, North Carolina 28301 CORRECTIVE ACTION PLAN March 11, 2024 U.S. Department of Housing and Urban Development Five Points Plaza Building 40 Marietta Street Atlanta, Georgia 30303 Mount Sinai Foundation, Incorporated respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings for the year ended December 31, 2022 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - Financial Statement Audit and Federal Award Program Audits Finding 2022-002 - U.S. Department of Housing and Urban Development, Mortgage Insurance Rental and Cooperative Housing for Moderate Income Families and Elderly, Market Interest Rate (Sections 221d(3) and (4) Multifamily - Market Rate Housing), CFDA #14.135 Recommendation: We recommend that management ensure supporting documentation is maintained for all disbursements from project operations. Action Taken: We agree with Finding 2022-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will ensure supporting documentation is maintained for all disbursements from project operations. If HUD has questions regarding this corrective action plan, please call (803) 873-2377. Sincerely yours, Dwayne Legrant President Omni Property Management and Development Managing Agent

Condition: The grant is a reimbursement type grant, as the grant agreement does not specifically indicate that it is an advance type grant. As such, all expenses should be recognized before applying for funding, or expended within a “reasonable” period subsequent to receipt of funds. Context: The Organization applied for grant drawdowns based on projections and expended funds greater than 30 days beyond receipt, resulting in the expenditure occurring in a different fiscal year than when the funds were received. Effect: The receipt of funds before expenditure was $708,288. Recommendation: The Organization should review internal policies related to drawdowns to ensure that drawdowns occur in compliance with Uniform Guidance. Managements Response: We agree with finding, and will follow prescribed recommendation.