Corrective Action Plans

Responsible Official's Response: In addition to our response to Finding 2023-001, we have hired a new Director of Human Resources as of December 2023. Most of the issues regarding record retention revolve around HR documentation. As such our new Director will have a significant impact on this process going forward more so in FY 24-25 rather than FY 23-24. We have taken steps to insure the Human Resources records are audit ready and we have implemented our own internal review process to insure record readiness.

Finding Number 2023-004 Period of Performance Corrective Action Plan (CAP) The State (DAS) will issue a memo requiring all departments to document the period of performance procedures performed. Additional training will be provided to ensure departments are complying. Anticipated Completion Date September 30, 2026 Responsible Person (Contact Details) Jonas M. Paul- Director (DAS) jpaulckdas@gmail.com Kayviann Hallers – Internal Control kayviannhallers@gmail.com

Finding Number 2023-003 Procurement, Suspension and Debarment Corrective Action Plan (CAP) A search on sams.gov for the selected vendors under this finding revealed each of them were not suspended or debarred. A memorandum has been drafted and will be issued to all departments and offices involved in procurement within Chuuk State Government. The memorandum outlines the requirement that all departments and offices must verify that any individual or business participating in procurement transactions is not listed on the SAMS.gov Exclusion list. A written work instruction on how to perform this verification will also be distributed to ensure a clear understanding of this procedure. A print out of this search will be included with each transaction file and saved among transaction files as proof of compliance. DAS has hired an Internal Auditor to assist with the timely completion of audits. Internal Auditor and team are in the process of converting their records system into a digital filing system to improve records management which will be easily available for audit and other subsequent requests. Anticipated Completion Date September 30, 2026 Responsible Person (Contact Details) Jonas M. Paul- Director (DAS) jpaulckdas@gmail.com Kayviann Hallers – Internal Control kayviannhallers@gmail.com

2023-006 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of twenty individuals receiving federal work study, we noted one individual (5%) was paid an incorrect pay rate for federal work study hours worked. We consider this condition to be an instance of noncompliance relating to the Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Corrective Action Plan: When rates of pay change, and Employee Authorization document is submitted through a series of individuals (Director of Financial Aid, Supervisor, VP, VP of Financial Services, Human Resources & the President) and signed/approved. This document is then received by the Payroll Coordinator. After payroll is completed, the VP of Financial Services thoroughly reviews all payroll items and verifies rate changes have occurred. Responsible Party for Corrective Action Plan: Payroll Coordinator & VP of Financial Services Implementation Date for Correction Action Plan: Implemented January 2023.

2023-003 Special Tests and Provisions – Inter-Program Fund Management Public and Indian Housing Program – CFDA Number 14.850 Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control, Material Noncompliance Condition: There were inter-program borrowings using federal funds which are unauthorized distributions, resulting in $3,943,604 of the total $4,164,790 in inter-program "due from" and "due to" balances lacking supporting documentation or reconciliation schedules. The unsupported balances primarily consist of significant amounts due to the Public Housing program, including $1,590,789 due to AMP 2 and $2,200,000 due to AMP 199 HOPE VI. These are offset by significant amounts owed by the Housing Choice Voucher program ($1,458,947) and the Central Office Cost Center ($2,190,705). Auditor’s Recommendation: To strengthen internal controls and ensure compliance, it is recommended that the Authority perform a detailed analysis to identify and document the specific transactions comprising the outstanding inter-program balances. Based on this analysis, a formal plan should be developed to resolve and settle these balances. To prevent a recurrence, the Authority should also establish and implement written policies that outline clear requirements for proper authorization, documentation, and timely settlement of any future inter-program transactions. Specifically, the inter-program amounts should be settled every month and balances should not be carried forward. Finally, ongoing compliance can be ensured by incorporating a monthly reconciliation of all "due from" and "due to" accounts into the regular financial closing process. Action Taken: Management has begun a detailed analysis to fully reconcile all unsupported inter-program balances by April 30, 2026. Following this, a formal plan to settle the balances will be presented to the Board by May 31, 2026. To prevent a recurrence, a new Inter-Program Transfer Policy—requiring written authorization and clear documentation—is being drafted for Board approval by June 30, 2026. These new controls will be supported by mandatory monthly reconciliation procedures to ensure ongoing compliance, with all corrective actions to be fully implemented by July 31, 2026.

2023-003: Allowable Costs of Indirect Costs Responsible Party: Libby Albers, Executive Director Implementation Date: 11/1/2025 The KAWS Executive Director requested reimbursements of audit expenses that included contractual invoices and billing for direct hours spent on the effort. However, the Director neglected to follow up with the independent account to transfer reimbursement of the personnel hours out of the grant and into the administrative project code. The KAWS Executive Director will request a P&L by job report from the accountant on an annual basis and again when a grant is closing to ensure that any costs recorded as direct or indirect administrative expenses have been moved to the administrative project code and out of the grant.

Finding 2023-001 Major Federal Program; 09.744050 – Legal Services Corporation – Basic Field Grant Compliance Requirements: Allowable Cost and Cost Principles Response and Corrective Action: The Chief Executive Officer (CEO) and LANWT accounting department will review and train on 45 CFR 1631 regarding the subject of Purchasing and Property Management. LANWT will review its policies and protocols to require prior purchase approval and exigent circumstances approval. Deadlines shall be calendared by the CEO and the accounting department whenever there is an exigent circumstance and approval will need to be requested within the 30-day notice period. The CEO will remain in periodic contact with LSC if any extenuating circumstances exist. The accounting manual will be updated with this protocol. Date of Completion: June 1, 2024 Person Responsible to Ensure Completion: Maria Thomas-Jones, CEO

Condition Found: In accordance with the loan terms, Peabody Place is required to annually fund a capital asset replacement reserve of $100,000, debt payment reserve in the amount of $111,696, and a resident asset depletion reserve and facility fill reserve each for $50,000. The Organization did not make the required annual deposits into the debt payment reserve, capital asset replacement reserve, resident asset depletion reserve and the facility fill reserve. Individual(s) Responsible for Corrective Action: Lynda P. Goldthwaite, Executive Director and Stacey Matott, Director of Finance Planned Corrective Action: Peabody Place sought a debt work out in 2025 that would allow for deferral of required deposits for six months until January 1, 2026. Anticipated Completion Date: December 31, 2024

For every program that Twin Oaks operates, there is an approved budget by the grantor agency that includes incentives for modifications and awards for youth behavior. Twin Oaks will strictly go by these approved budgets and better document the purpose. In addition, Benjie Read CFO and Felecia Read Staff Accountant, will educate financial staff on using proper allocation schedules and proper supporting documentation. Expense allocation schedules will be updated periodically whenever program additions or deletions occur with a minimum of twice per year. Twin Oaks has already replaced expense reproting software that was inadequately providing backup documentation with a new system which has greatly improved our accuracy and documentation. Also, our systems have greatly improved since we started with quarterly reporting to our CBCs, especially NWF Health Network, who have greatly assisted in our correct allocation of expenses. This education process will be completed within 90 days of completion of audit.

For every program that Twin Oaks operates, there is an approved budget by the grantor agency that includes incentives for modifications and awards for youth behavior. Twin Oaks will strictly go by these approved budgets and better document the purpose. In addition, Benjie Read CFO and Felecia Read Staff Accountant, will educate financial staff on using proper allocation schedules and proper supporting documentation. Expense allocation schedules will be updated periodically whenever program additions or deletions occur with a minimum of twice per year. Twin Oaks has already replaced expense reproting software that was inadequately providing backup documentation with a new system which has greatly improved our accuracy and documentation. Also, our systems have greatly improved since we started with quarterly reporting to our CBCs, especially NWF Health Network, who have greatly assisted in our correct allocation of expenses. This education process will be completed within 90 days of completion of audit.

With the support of a new leadership team, Jefferson Parish is committed to strengthening oversight and monitoring federal grants financial and compliance activities. To enhance reliability, the Parish has engaged Deloitte & Touche LLP as a consultant to assist with improving documentation procedures and strengthen internal controls supporting financial and compliance activities going forward. As part of this effort Jefferson Parish and Deloitte are working across Finance, Accounting, and programmatic departments to establish improved federal grants governance and policy. This includes quarterly oversight and review processes and procedures to monitor the use of federal funds and confirm that compliance activities are occurring. This also includes improved preventative controls to require the performance of due diligence activities for each federal fund sub-recipient or individuals receiving federal assistance prior to the awarding or disbursement of federal funds. The Parish will also develop a policy and communicate annually to all departments the requirements to report to the appropriate authorities, including the Louisiana Legislative Auditor's Office and the Jefferson Parish District Attorney's Office. Community Development Director Stephanie Brumfield, Interim Finance Director Victor LaRocca and Risk Management Director Maria Leon will develop and communicate the policy for reporting fraud which should be enacted by January of 2026.

Finding 2023-002 - Equipment and Real Property Management Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: All capital expenditures will require documented prior approval from the grantor agency before encumbrance. Property records will be updated and maintained in accordance with 2 CFR 200.313 and 200.439. A physical inventory will be conducted and reconciled at least once every two years. Anticipated Completion Date: October 1, 2025

Finding 2023-001 - Special Tests and Provisions: Wage Rate Requirements Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: Wage rate clauses will be included in all federally funded construction contracts. Contractors and subcontractors will be notified in writing of prevailing wage requirements, and certified payrolls will be required and reviewed for all weeks for which construction work is performed. Anticipated Completion Date: October 1, 2025

Based upon current auditor’s recommendation, PAX established an effort verification reporting system. This system was launched in FY23 and enhanced in FY24 with great specificity and fuller allocation information. The latest system will accurately capture the effort spent by each employee on specific grants, ensuring proper documentation of allocation of wages and salaries to the respective federal awards.

Setting a process up for getting federal wage requirement when projects are being completed. The district will also make sure that the proper training and time will go into allowable cost.

We will allocate shared costs appropriately among federal awards

2023-009- Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: American Rescue Plan Act / Coronavirus State Fiscal Recovery Fund (ARPA) Assistance Listing Number: 23.027 Federal Award Identification Number and Year: Various Pass-Through Agency: Pennsylvania Department of Health and Human Services Pass-Through Number(s): Not Available Award Period: 1/1/2023 – 12/31/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Condition: Policies and controls in place regarding the completeness of the SEFA were not properly functioning. Within the supporting listing of expenses relating to ARPA expenditures, multiple transactions were identified as 2022 fiscal year expenditures that were included in the 2023 expenditure total. The County revised the 2023 SEFA to exclude the 2022 expenditures. Recommendation: We recommend management should review the process of recording federal expenditures to determine expenditures are being included in the appropriate fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned and taken in response to finding: The reason for the finding’s recurrence is in part a result of the timing of when the finding was issued. For example, the 2022 Single Audit was issued in August 2024. At this point, the 2023 fiscal year was already complete. Additionally, the implementation of corrective actions are in progress, including providing training, oversight and guidance to departments administering the grants, but these efforts take time to complete and/or are ongoing. A Deputy Controller of Grant Accounting was hired in February 2023, and a Manager-Grant Accounting was hired in July 2024, after working in this capacity as a temporary staff member since mid-2023. The County approved an additional full-time grant accounting position in May 2025 and will begin recruiting for this position in June 2025. These positions are responsible for establishing accounting policies based on best practices for grant-related activities, developing and providing training and resources to grant- funded departments, reviewing grant-related accounting in the Infor system, preparation of the annual SEFA, and assisting in the facilitation and preparation of documents needed for the Single Audit. The work performed by these positions had been vacant since the departure of Internal Audit Staff who helped General Accounting prior to the 2021 audit as well as the SEFA. Several changes have been made since the grant accounting team was created including the following: The grant accounting team is developing streamlined and standardized SEFA templates for each department for SEFA preparation. The expenditures reported on each SEFA are being compared to the financial information in the GL where possible to ensure all appropriate expenditures are included. Additionally, we are incorporating tracking of lifetime grant expenditures into the SEFA process to ensure no expenditures are missed due to cut off or timing issues. In 2023, the grant accounting team created a Montgomery County Grant Repository. This repository is used to store all grant agreements awarded to the County. Departments submit grant information to the repository upon notification of grant award. The grant accounting team reviews the Grant Repository when preparing the SEFA to ensure no grant programs are inadvertently left off of the SEFA. Additionally, the availability of the Grant Repository enables members of the accounting, finance and grant departments to quickly access grant award information when needed for audits, reporting, or other requirements. The grant accounting team is continuing to review and update the County’s Grant Accounting policies and is working closely with departments to understand their utilization of Infor to account for grant- related activities. As these policies are formalized, we will continue to provide training and resources; in late 2023, the County hired an outside trainer to provide an in-depth training on the accrual method of accounting, grant accruals, and the treatment of grant revenue. The Grant Accountant provided training in April 2024 to explain and outline the SEFA and Single Audit processes. Grant-funded departments received a two-day training on utilization of the Grant Management components of Infor in February 2024. We are also providing guidance and education to departments on the differences in timing of various grant fiscal years and how these impact the financial audit, SEFA and Single Audit. For example, departments must understand how to report expenditures and receipts in the correct period regardless of the fiscal year associated to the contract (State: July-June; Federal: October-September; County: January-December) and understand how these amounts reconcile to the amounts reported to the funding agencies. The accounting department continues to work with departments to emphasize the importance of submitting financial documentation timely and reviewing what is in the General Ledger promptly at the end of each month. The Finance department is performing quarterly reviews with departments to go over financial status, including grant financials. Departments are continuing to utilize Project Codes and other components of Infor’s Grant Management System to ensure the proper accounting of grant-related expenses, receipts, and revenues in the GL. Name(s) of the contact person(s) responsible for corrective action: Thomas Landauer and Fonta Reilly Planned completion date for corrective action plan: September 2025

2023-008 – Reporting Federal Agency: U.S. Department of the Treasury Federal Program Name: Emergency Rental Assistance Program (ERAP) Assistance Listing Number: 23.023 Federal Award Identification Number and Year: Various Pass-Through Agency: Pennsylvania Department of Health and Human Services Pass-Through Number(s): Not Available Award Period: 1/1/2023 – 12/31/23 Type of Finding: Significant Deficiency in Internal Control Over Compliance Condition: Policies and controls in place regarding the completeness of the SEFA were not properly functioning. Within the supporting listing of expenses relating to ERAP expenditures, six transactions were identified as prior fiscal-year expenditures that were included in the unadjusted 2023 expenditure total. The County revised the 2023 SEFA to exclude the 2022 expenditures. Recommendation: We recommend management should review the process of recording federal expenditures to determine expenditures are being included in the appropriate fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned and taken in response to finding: The reason for the finding’s recurrence is in part a result of the timing of when the finding was issued. For example, the 2022 Single Audit was issued in August 2024. At this point, the 2023 fiscal year was already complete. Additionally, the implementation of corrective actions are in progress, including providing training, oversight and guidance to departments administering the grants, but these efforts take time to complete and/or are ongoing. A Deputy Controller of Grant Accounting was hired in February 2023, and a Manager-Grant Accounting was hired in July 2024, after working in this capacity as a temporary staff member since mid-2023. The County approved an additional full-time grant accounting position in May 2025 and will begin recruiting for this position in June 2025. These positions are responsible for establishing accounting policies based on best practices for grant-related activities, developing and providing training and resources to grant- funded departments, reviewing grant-related accounting in the Infor system, preparation of the annual SEFA, and assisting in the facilitation and preparation of documents needed for the Single Audit. The work performed by these positions had been vacant since the departure of Internal Audit Staff who helped General Accounting prior to the 2021 audit as well as the SEFA. Several changes have been made since the grant accounting team was created including the following: The grant accounting team is developing streamlined and standardized SEFA templates for each department for SEFA preparation. The expenditures reported on each SEFA are being compared to the financial information in the GL where possible to ensure all appropriate expenditures are included. Additionally, we are incorporating tracking of lifetime grant expenditures into the SEFA process to ensure no expenditures are missed due to cut off or timing issues. In 2023, the grant accounting team created a Montgomery County Grant Repository. This repository is used to store all grant agreements awarded to the County. Departments submit grant information to the repository upon notification of grant award. The grant accounting team reviews the Grant Repository when preparing the SEFA to ensure no grant programs are inadvertently left off of the SEFA. Additionally, the availability of the Grant Repository enables members of the accounting, finance and grant departments to quickly access grant award information when needed for audits, reporting, or other requirements. The grant accounting team is continuing to review and update the County’s Grant Accounting policies and is working closely with departments to understand their utilization of Infor to account for grant- related activities. As these policies are formalized, we will continue to provide training and resources; in late 2023, the County hired an outside trainer to provide an in-depth training on the accrual method of accounting, grant accruals, and the treatment of grant revenue. The Grant Accountant provided training in April 2024 to explain and outline the SEFA and Single Audit processes. Grant-funded departments received a two-day training on utilization of the Grant Management components of Infor in February 2024. We are also providing guidance and education to departments on the differences in timing of various grant fiscal years and how these impact the financial audit, SEFA and Single Audit. For example, departments must understand how to report expenditures and receipts in the correct period regardless of the fiscal year associated to the contract (State: July-June; Federal: October-September; County: January-December) and understand how these amounts reconcile to the amounts reported to the funding agencies. The accounting department continues to work with departments to emphasize the importance of submitting financial documentation timely and reviewing what is in the General Ledger promptly at the end of each month. The Finance department is performing quarterly reviews with departments to go over financial status, including grant financials. Departments are continuing to utilize Project Codes and other components of Infor’s Grant Management System to ensure the proper accounting of grant-related expenses, receipts, and revenues in the GL. Name(s) of the contact person(s) responsible for corrective action: Thomas Landauer and Fonta Reilly Planned completion date for corrective action plan: September 2025

Finding 2023-006 Lack of Internal Control over Cash Management Type of Finding: Material Weaknesses Name of Contact: Adela Lane, Executive Director Corrective Action Plan: 1. Strengthen the payment review process: • Action: Enforce and document a stricter segregation of duties in the payment process. This will ensure the individual requesting a payment is not the same person who authorizes the payment. • Details: All payment requests must be cross-referenced with a corresponding invoice or receipt and reviewed and approved by an authorized department head. This Department Head must not be the one who submitted the initial request. 2. Implement a two-tiered review for cash receipts: • Action: Establish a formal two-tiered cash receipts process to enhance accountability and accuracy. • Details: o Tier 1: The individual receiving and logging cash receipts will immediately perform a preliminary count and documentation. o Tier 2: A separate, authorized staff member will perform a second, independent review of the cash receipt records and verify the funds against the deposit slip before the funds are deposited. 3. Standardize training and onboarding for all staff: • Action: Develop a standardized training curriculum on financial management policies and procedures, including a dedicated section on cash management best practices. • Details: o All new permanent and staff members will undergo mandatory training on the updated policies. o Training will cover the importance of internal controls, specifically emphasizing segregation of duties in cash handling. o The Executive Director will meet with all new finance and administrative staff within their first two weeks to review proper protocols and emphasize the organization's commitment to financial controls. 4. Introduce periodic, surprise cash audits: • Action: Conduct unannounced cash counts and reconciliations to ensure compliance with procedures. • Details: An authorized, independent party will perform these surprise audits quarterly to check cash on hand and compare records against financial systems. 5. Enhance oversight and reporting: • Action: The Executive Director will provide regular updates on the implementation of these corrective actions to the Native Village of Point Hope Tribal Council. • Details: A formal report will be presented quarterly, outlining the progress of the corrective actions and any findings from the new oversight procedures. This provides a clear accountability mechanism. Proposed Completion Date: Ongoing, starting in early 2026.

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Tyler Pearson, Clerk Treasurer Contact Phone Number and Email Address: 574-739-1416 clerktreasurer@cityoflogansport.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: As a measure of corrective action, I will be implementing a check sheet that will be attached to every claim sheet. This new procedure requires that you go through the check sheet and initial each item to ensure that all procedures have been followed correctly before submission. Additionally, I will also maintain a check sheet in my office since I am the last person to review each claim. This will help to ensure thoroughness and accuracy in our claims processing. Furthermore, moving forward, any grant funds will be placed into their own individual funds and distributed through an individual account. This approach will allow us to track payments for any expenses associated with these funds more effectively. Additionally, the BOT expenditure is done and in the future we will do a better job. Anticipated Completion Date: October 31,2025

2023-010 – Material Weakness & Noncompliance, Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance: FEMA Disaster Grants (ALN 97.036) Corrective Action: Develop an improved detailed tracking system for force account labor and materials. Require contemporaneous documentation of payroll and invoices tied to FEMA projects. Grants Officer to oversee federal disaster recovery funds. Timeline: New procedures adopted October 2025; effective for any new FEMA claims. Responsible Party: Grants Officer in coordination with relevant departments

Finding 2023-006 Due to cash flow constraints, the Project was not able to repay the replacement reserve. The Project will repay the replacement reserve when cash is available. If cash becomes available, the anticipated completion date is June 30, 2024.

Finding 2023-005 Due to the financial situation the Project is in at June 30, 2023, making this deposit is impossible. HUD has agreed to suspend the monthly required debt service savings deposit effective September 1, 2019. Management is negotiating with HUD to get the past debt service saving deposit requirement suspended permanently. If management is successful in negotiations with HUD, the anticipated completion date is June 30, 2024.

Finding 2023-004 Due to cash flow constraints, the Project was not able to repay the nonprofit sponsor’s foundation. The Project will repay the nonprofit sponsor’s foundation when cash is available. If cash becomes available, the anticipated completion date is June 30, 2024.

Finding 2023-003 Due to cash flow constraints, the Project was not able to repay the nonprofit sponsor’s foundation. The Project will repay the nonprofit sponsor’s foundation when cash is available. If cash becomes available, the anticipated completion date is June 30, 2024.