Corrective Action Plans

Department of Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Finding 2023-003 – Education Stabilization Fund – ESSER III AL No. 84.425U Condition: During our test of controls over compliance it was noted that there are expenditures charged to the Education Stabilization Fund – ESSER III for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Criteria: The Period of Performance for the Education Stabilization Fund – ESSER III was October 4, 2021 through September 30, 2024. Context: During our test of expenditures and review of the general ledger against the Education Stabilization Fund – ESSER III grant as it is related to compliance it was noted that the School paid in full a four year lease from 3/1/23 to 2/28/27 and charged 10/1/23 to 2/28/27 to the Education Stabilization Fund – ESSER III grant in the amount of $190,869 and thus the period from 10/1/24 to 2/28/27 would be outside the period of performance and thus would not be an allowable cost. Effect: Assabet Valley RTHS 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 charged to the Education Stabilization Fund – ESSER III grant whose service period was beyond the grant end date of September 30, 2024 was in the amount of $135,005. Cause: Grant should have been amended Identification as a Repeat Finding: N/A Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that expenditures charged to the grant is within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Responsible for Corrective Plan: Maria Silva, Director of Business Operations Estimated Completion Date: 12/31/2024 Action Taken: The District agrees with the recommendation and will work with those writing the grants.

Department of Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Finding 2023-002 – Education Stabilization Fund – ESSER III AL No. 84.425U Condition: During our test of controls over compliance it was noted that an employee’s payroll charged to the Education Stabilization Fund – ESSER III major program was for services that was not included as part of the grant application/budget. Criteria: Costs charged to the major program should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our review of payroll charged to the major program it was noted that one of the employees charged to the grant was for work as a School Adjustment Counselor that was charged to the Instructional Staff budget of the grant, which does not support the services charged. Thus the payroll expense would be unallowable. Effect: Assabet Valley RTHS was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: $76,676.89 Cause: Grant should have been amended Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that payroll expenditures charged to the grant is allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Maria Silva, Director of Business Operations Estimated Completion Date: 12/31/2024 Action Taken: The District agrees with the recommendation and will work with those writing the grants.

Action to be taken – Future internal approval of all timesheets will include first approval by the immediate supervisor, reviewing total hours worked per week, grants billed, and total hours worked. There will be a second approval by an outside financial management firm when they process the payroll to prevent errors in overpayments. Estimated completion date – In September 2024 the new executive director mandated her approval or that of the board treasurer for any expenses. We are in the process of onboarding with the new financial management company with the anticipated start date of October 1, 2025 (the beginning of 2026 fiscal year).With this addition to our process, payroll will be processed off site by a third party. Responsible person – Carla Filkins, Executive Director and Julie Rushing, Board Treasurer

Auditor's Recommendation: The auditor recommends the Organization enhance the design of its control activities and procedures over the allocation percentage forms used throughout the year to ensure the staff know how to apply percentages and are using the correct approved allocation form for the period in the year. Management’s Response: A process was implemented in fiscal year 2024 to address this issued and included the following: • The allocation form was updated and is now clearly labeled with the period and type of expense for which it applies. • The Executive Director communicated the revision of all forms to staff involved in the allocation process, followed by a training session to ensure understanding and proper application of the form. • A monthly review of the process, whereby allocation forms were audited for current updates and application consistency. Due date of completion: August 31, 2024 Responsible Official: Executive Director, Michelle Crain

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203(Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Thirty-two (32) names were selected from the new move-in list and those names were to be traced to the waiting list to verify new move-ins were chosen in an order that was in accordance with the Authority’s policy. It was determined that six (6) out of thirty-two (32) new move-ins selected could not be traced with any certainty back to the Authority's waiting list. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $35,098 14.879 - Mainstream Vouchers - $13,796 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers programs are in material non-compliance with the special tests and provisions type of compliance related to selections from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Mainstream Vouchers and Emergency Housing Vouchers Federal Assistance Listing Numbers: 14.879 and 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were failed inspections that did not pass reinspection within 30 days without penalty. Context: There are approximately 172 units with failed inspections. Of a sample size of seventeen (17) failed inspections, two (2) failed inspections did not pass reinspection within 30 days. HAP was not abated nor was the tenant evicted. Our sample size is statistically valid. Known Questioned Costs: 14.879 - Mainstream Vouchers - $1,002 14.EHV - Emergency Housing Vouchers - $7,555 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly performed HQS inspections in compliance with program requirements following the expiration of HUD waivers as a result of insufficient staffing . Effect: The Mainstream Vouchers and Emergency Housing Vouchers programs are in non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor, and will design and implement internal controls over compliance in order to ensure all necessary failed HQS inspections with life threatening deficiencies are addressed within 24 hours and all other deficiencies are addressed within 30 days. Shannon Koenig and CEO, executive director, is responsible for implementing this corrective action by December 31, 2024.

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility. Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 6,531 units. Of a sample size of seventy-seven (77) tenant files, the following was noted: - Section 214 citizen declaration form missing in 15 files - HUD 9887 consent to release information form missing in 2 files - Original application missing in 1 file - Annual inspection missing in 1 file - Lead based paint form missing in 4 files - Verification of income missing in 6 files Our sample size is statistically valid. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $36,728 14.879 - Mainstream Vouchers - $13,028 14.EHV - Emergency Housing Vouchers - $1,272 Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor, and will make the several changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.

Chairman of the Board of County Commissioners: Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Anticipated Completion Date: 6/30/2025 Responsible Contact Person: Myles Davidson, BOCC Chairman

Finding No.: 2023-003 Condi􀆟on: SEDOL submited grant expenditure reports for reimbursement without having sufficient support for expenditures claimed, resul􀆟ng in reimbursements greater than allowable costs. Plan: Management will implement a process to properly budget, track and monitor grant expenditures and create an improved review and oversight process. An􀆟cipated Date of Comple􀆟on: 6/30/2026 Name of Contact Person: Dr. Stephen Johns, Co-Interim Assistant Superintendent

2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. Recommendation: The Authority should develop a plan based on budgeting and monitoring of COCC expenses to have the ability to reimburse funds to the Public and Indian Housing Program. Action Taken: To restore financial integrity and ensure proper use of COCC funds, the Authority will take the following actions: 1. COCC Optimization and Budget Reform: Develop and implement a proper, balanced COCC budget that reflects actual operating costs and allocates shared services appropriately. Establish budget accountability protocols, including monthly budget-to-actual reviews and variance reporting to the CFO, CEO, and Board. 2. Training and Capacity Building: Provide training for finance staff on COCC operations, HUD’s Asset Management model, and best practices for cost allocation and shared services. Engage external consultants to support financial modeling and long-term sustainability planning for RAD and LIHTC properties. 3. Shared Services Agreement: Formalize a Consulting and Shared Services Agreement to ensure that COCC services are appropriately billed and reimbursed by other programs. Monitor inter-program transactions to ensure compliance with HUD’s financial management requirements. 4. Salary Allocation and Cost Tracking: Conduct a salary allocation study to ensure that staff time is distributed adequately across programs. Implement time-tracking tools and cost allocation methodologies that align with HUD guidance and OMB Uniform Guidance. Effective Date: June 3, 2025 Contact Information Dr. Michael C. Threatt, Chief Executive Officer Sanford Housing Authority 317 Chatham Street Sanford, North Carolina 27330 (919) 776-7655

2023-002 Procurement and Suspension and Debarment – Proper Documentation 14.872 Public Housing Capital Fund Material Weakness in Internal Control, Material Noncompliance Condition: The Authority did not have adequate controls over compliance with federal regulations regarding procurement. During the audit period, Authority paid amounts to a contractor for unit turnover and renovation totaling $121,125 without documenting that it had properly procured these services. Recommendation: Authority personnel responsible for acquiring goods and services should receive additional training regarding the federal standards for procurement. Action Taken: To address the identified deficiencies and restore compliance, the Authority will implement the following corrective actions: 1. Training and Capacity Building: Provide comprehensive online and in-person training on procurement, contract management, and budget accountability for all relevant staff. Train management staff on participating in procurement selection committees and evaluating Requests for Proposals (RFPs), Requests for Quotations (RFQs), and Invitations for Bids (IFBs). Include budget literacy and financial planning modules in all staff training programs to ensure understanding of budget development, monitoring, and compliance. 2. Third-Party Assessment and Policy Updates: Engage a third-party firm to assess procurement, contract management, and budget oversight operations. Revise the current procurement policy, standard operating procedures (SOPs), and budget management protocols to ensure alignment with best practices. Update internal controls and financial policies to ensure alignment with HUD regulations and best practices. 3. Process Improvement and Technology Integration: Develop a process map based on assessment findings to streamline procurement and budget workflows, thereby reducing risk. Implement an affordable, user-friendly eProcurement software solution tailored to the affordable housing sector. Evaluate the need for a dedicated staff member to manage the eProcurement system, including vendor management, proposal evaluation, contract oversight, reporting, and system integration. 4. Transparency and Outreach: Create and maintain a procurement page on both the current and new Authority websites. Publicize procurement opportunities through social media and other outreach channels. Publish budget summaries and procurement plans to promote transparency and stakeholder confidence. 5. Governance and Accountability: Ensure all relevant staff, including finance, executive leadership, asset management, and others, are trained in procurement, contract management, and budget accountability. Reinforce best practices by designating the Chief Executive Officer as the sole Contracting Officer authorized to enter into agreements on behalf of the Authority. Establish regular internal audits and budget reviews to monitor compliance and performance.

Incorrect Pell Calculations Planned Corrective Action: A process will be implemented to verify Pell is correctly awarded before disbursements are made. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Need Analysis Planned Corrective Action: All scholarships will be marked as estimated financial assistance and an awarding check for need will be done accurately before final distribution. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

Name of auditee: Trinity Housing Corporation of Greeley HUD auditee identification number: 101-98145 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended October 31, 2023 CAP prepared by Name: Tashawndra Welch Position: Chief Financial Officer Telephone number: 901-435-7764 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding #2023-001 Comments on the Finding and Each Recommendation: For the year ended October 31, 2023, the Corporation paid management fees to the Agent in excess of the fees earned resulting in prepaid management fees of $8,370 at October 31, 2023. Action(s) taken or planned on the finding: The Corporation concurs with the finding and agrees with the auditor’s recommendation.

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

Contact Information: Sharon Hunt, Interim Chief Financial Officer, Dallam Hartley Counties Hospital District Audit Finding Reference Number: 2023-003 Planned Corrective Action: DHCHD has contracted with another payroll provider. Human Resources staff will work with the payroll provider to ensure that appropriate documentation regarding pay amounts and other essential payroll and personnel data is maintained on each employee. Anticipated Completion Date: Completed as of October 1, 2024

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update: History and Board Actions: In FY 2021, Via Hope experienced a significant loss of revenue due to the ending of contracts from its two primary funding streams – the Health and Human Services Commission and the Hogg Foundation for Mental Health. This loss of revenue resulted in the Board recommending and approving the reduction of staff and the departure of the CEO. In FY 2022, the Board recommended and approved the termination of its Accounts Manager and the former Board Chairman stepped in to voluntarily manage the finances until the organization could make other arrangements. The former chairman stepped down from his role and an election of officers was held to install a new Chair. By January 2022, with new revenue coming into the organization, the Board selected a new CEO and in December 2022, a new accounts manager was hired. Once the new accounts manager began reconciling the accounts, a pattern of questionable expenditures became evident with PayPal and other accounts. The CEO and staff informed the Board of what appeared to have happened and recognizing its fiduciary responsibility, the Board approved the engagement of a forensic audit by an external audit firm, The Wesley Peachtree Group (WPG) of Atlanta, Georgia. The forensic audit resulted in findings that fraudulent activity in the amount of $233,000 was likely to have occurred. As a result, the CEO was instructed to file an insurance claim with Frost Insurance. To process the claim, Frost required the involvement of law enforcement which was approved by the Board. Formal investigations were launched and remain ongoing with the Austin Police Department and the Travis County District Attorney's office. Recently, law enforcement met with the Board and provided an update on the investigation. Subsequently, the CEO was requested to follow up with the insurance carrier and state regulatory agencies to ensure the prompt receipt of its insurance claim from PayPal and other potential sources. II. FINDINGS AND RECOMMENDATIONS: Finding 2023-001 - Internal Control Deficiencies (Material Weakness) a) Time and Effort, Payroll and Human Resource Forms and Contracts - In response to the finding, Management will require monthly Time and Effort reports for each employee, develop new human resource forms, and update staff contracts at the beginning of the fiscal year. b) Drawdowns and Written Approvals - With the addition of the new Finance staff member in January 2025, management will initiate a written approval process. All payroll adjustments, drawdowns, credit card purchases, and payments will require invoices, receipts, and written approvals before payment is made. The Accounting Manager will also work with the CEO to ensure that staff provide receipts promptly and that journal entries are recorded on a monthly basis. c) Receipts, Written Approvals, PP&E Schedule - Receipts and written approvals were addressed in Response (C). While the organization maintains an equipment log, we will establish a formal Property, Plant, and Equipment Schedule (PP&E), particularly noting equipment purchased with federal funds. d) Segregation of Duties - Management has begun the process of interviewing qualified staff to segregate duties in the Finance office. This will ensure that one individual will no longer be responsible for handling funds, payments, reconciliations, and General Ledger (GL) postings. The individual will be in place by January 2025.

2023-012 Maintenance of Effort (Material Weakness) Management’s Response: Training has been more of a self-learned activity but we are trying to get these done. Working with the auditors helped the most to understand what these reports should look like. The hope is to have 25-26 MOE’s completed in the Fall of 2025. Name of Contact Person and Completion Date: Toni Butterfield Anticipated Completion Date – 10/1/2025

2023-011 Excess Food Service Fund Balance (Material Weakness) Management’s Response: We completed and Excess Balance Use of Funds report and worked with the State to understand exactly the parameters of this/ The funds were spent down and we are working hard to make sure to stay under the three months of expenses as worded in CFR Title 7, 210.14(b). Again management is trying to take on a bigger role as this monitoring was not considered prior to COVID. Fund Balances at year end averaged no more than $10,000. Name of Contact Person and Completion Date: Toni Butterfield Anticipated Completion Date - Immediately

Finding Number: 2023-004 Finding Title: Eligibility Program: 21.023 COVID-19 – Emergency Rental Assistance Program Name of Contact Person Responsible for Corrective Action: Daniel Rahkola, Division Director Finance Corrective Action Planned: Staff will be retrained on the procedures to ensure compliance with the needed standards. Anticipated Completion Date: June 30, 2025

Child Nutrition – Report Testing Recommendation: We recommend that the District reviews its procedures and controls over reporting for the Child Nutrition Cluster program to ensure all reports are accurately reporting information and are reviewed by someone other than the preparer and that review is documented prior to submission of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will review its procedures over its reporting of claims to MDE to ensure claims made to MDE is properly supported by the District's meals count. Name(s) of the contact person(s) responsible for corrective action: Tariro Chapinduka, Director of Business Services Planned completion date for corrective action plan: June 30, 2025

As noted in the finding, the significant staff turnover and financial constraints during the audit period caused some disruption in our ability to provide the necessary documentation for certain transactions. In light of this, we have developed and implemented a corrective action plan to ensure full compliance with 2 CFR 200, grant agreements, and cost principles going forward. 1. Strengthening Documentation Procedures: o Community Resource Center, Inc. has committed to implementing a process in which all transactions will be supported by actual invoices and all reimbursement requests will be submitted with corresponding supporting documentation. This will include both the original invoices and any other necessary backup materials. o Community Resource Center, Inc. is working with a financial consultant (start date on November 1, 2024), to audit and refine the financial systems, with particular emphasis on improving the accuracy and transparency of our documentation processes. The financial consultant will also assist in ensuring that all future costs align with the requirements of the funding agency and the OMB guidelines. 2. Review and Update of Internal Controls: o In response to the finding, Community Resource Center, Inc. has begun revising internal controls to ensure that adequate checks and balances are in place, especially in times of staff turnover. This includes designing more robust systems for tracking and documenting all costs related to grants, ensuring that all documentation is easily accessible for audit and review purposes. o A dedicated team will be assigned to monitor compliance with the internal control processes, and we will conduct regular internal reviews to verify that supporting documentation for all transactions is complete, timely, and accurate. 3. Contingency Planning for Staff Turnover: o Recognizing the impact of turnover, Community Resource Center, Inc. is formalizing a contingency plan for future staff changes. This plan will include clear guidance on the retention and transfer of all financial records, as well as designating backup staff with sufficient training and authority to oversee and maintain compliance with all financial requirements. We will also implement cross-training for key financial personnel to ensure continuity and consistency in the event of unexpected departures. 4. Ongoing Staff Training: o Community Resource Center, Inc. is committed to providing ongoing training to staff responsible for financial reporting and compliance. This will ensure that all staff involved in grant transactions understand the requirements set forth in 2 CFR 200 and other applicable regulations. Community Resource Center, Inc. will also work with the financial consultant to identify and address any skill gaps within the team. 5. Monitoring and Audit of Corrective Actions: o Community Resource Center, Inc. will establish regular internal monitoring and audits of these corrective actions to ensure they are being followed effectively. This will include periodic spot-checks of transaction documentation to ensure completeness and accuracy, as well as regular reviews of our internal controls and procedures to ensure their ongoing effectiveness.

Prepared by: Kevin Jacobs Date Prepared: 7-3-24 Person Responsible for Corrective Action Plan: Kevin Jacobs Jeff Dobson Anticipated Completion Date: 7-3-24 Official's Response: To be clear the documents had to be presented to FEMA to get reimbursement, this was done. The Fiscal Court will endeavor to make sure the FEMA files are updated and complete after FEMA reimbursement.

Condition: As a result of transition in the finance department and lack of formal filing procedures, we noted an instance in which the support for a portion of an authorized voucher could not be located. Corrective Action Taken or Planned: In conjunction with the hiring of a professional services firm for accounting and finance support, PHIMC will evaluate current record keeping system and ensure supporting information for submitted vouchers is maintained and accessible. Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Karen Reitan, President and Chief Executive Officer Management Response: Management concurs with the finding.