Corrective Action Plans

2023-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 – ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation. Planned corrective action: FY2024 contracts with subrecipients have been updated with all the required language. Responsible party: Chief Financial Officer Anticipated completion date: September 30, 2024

As communicated in the District’s response to the prior audit finding, the District does not concur with the SAO’s interpretation of unmet need in the 2021-2022 audit nor does it concur with the same finding for the audit of the 2022-2023 fiscal year. We believe all Chromebook purchases were allowable and devices were only provided to those with an unmet need. We concur with SAO that we did not retain adequate documentation indicating which staff and students received hotspots and appreciate that SAO noted that there was an urgent need to distribute hotspot internet services to students in order that they could participate in remote learning, and that this urgency and extenuating circumstances resulted in this situation. We recognize there was an error associated with vendor credits in the amount of $2,751.10 but did not claim reimbursement for the other credits totaling $8,898.90 as indicated in the audit finding. We will work to improve our process regarding credits on future invoices. The District will continue to work with the FCC to resolve this finding.

Procurement Recommendation: We recommend that the Organization follow the current policies and procedures over covered transactions and to maintain supporting documentation of the process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Society has reviewed the procurement policy with staff, emphasized the importance of following, and will ensure that adequate documentation is retained. Name(s) of the contact person(s) responsible for corrective action: Kelly Moritz, Vice President of Finance and Contracts Planned completion date for corrective action plan: December 31, 2024

Grant Reimbursement Requests (Indirect Costs and Cash Management) Recommendation: We recommend that the Organization follow the current policies and procedures over grant reimbursement transactions to maintain documentation supporting the request. This should include all supporting documentation and back-up, and preparer and reviewer sign-offs and dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Society was short of trained billing staff due to employee leave and has provided training to additional back-up staff for future use. Name(s) of the contact person(s) responsible for corrective action: Kelly Moritz, Vice President of Finance and Contracts Planned completion date for corrective action plan: December 31, 2024

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Return of Title IV funds calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand calculation and timing of returns. It should also be noted that in the current award year, CMN has moved to a model where attendance taking is not required, so staff is working with faculty and students to ensure timely notification of withdrawal and reviewing final grades at the end of the term in order to ensure all students needing a R2T4 calculation have one performed.

In order to address this audit finding, CMN financial aid staff plans to seek continual improvement in the areas relating to Pell calculations. Through both Federal Student Aid and National Association of Financial Aid Administrators (NASFAA), staff will complete trainings to understand all aspects of calculating awards, as well as staying up to date on regulatory changes through our student information system. In addition to more training in this area, priority will be placed on rechecking and auditing Pell awards so that they are reviewed during the award year. Staff has already begun reviewing fall 2023 Pell awards for accuracy and will continue to review awards as terms move forward.

Finding 2023-002 Corrective Action Plan The College acknowledges that funds withdrawn for these subprograms were not disbursed in a timely manner. The College notes that although the funds were disbursed after the period required by the program (within 3 days of withdrawal for non-student aid expenses), the expenses paid were allowable under the guidance of the program. The College’s staff and management developed a checklist in response to Finding 2022-005 from the prior year to ensure that reporting, filing, and disbursement requirements for all grants will be met. The College’s management notes that these Federal programs have expired and does not anticipate further funding related to the Education Stabilization Fund. Anticipated Completion Date The College anticipates completion of this corrective action on or before August 31, 2024. Name of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Ross Holgado – Manager of Financial Reporting

Finding Number: 2023-004 Condition: We were not able to verify that the U.S. citizenship for six of the 14 participants tested for the Talent Search program as management did not retain support for eligibility determination. Planned Corrective Action: Management concurs with the recommendation and will implement the proper internal controls to ensure all applications are complete and accurate. This is being accomplished by building out the internal accounting department, which includes adding a grants director to the team. Contact person responsible for corrective action: Brian Fredericks, Interim CFO Anticipated Completion Date: July 1, 2024

Audit Finding Reference: 2023 - 002 Planned Corrective Action: The two files noted for missed inspections have since been scheduled for reinspection, and one passed HQS inspection on 3/14/24. The other was scheduled for inspection on 3/12/24 and resulted in a Broken Scheduled Appointment (BSA). A second inspection was conducted on 3/28/24. BRHP has added two elements to the reporting process for inspections. The weekly leasing report now identifies failed inspections within the period. The second element is the Inspection Audit report. BRHP has increased the reporting metric from monthly to bi-weekly and included a pivot table to ensure the report is user friendly to staff that are responsible for reviewing. Both changes allow for greater visibility and frequency to ensure missed inspections are identified. Name of Contact Person: FaShaunDa Walton, Housing Mobility Director and Pete Cimbolic, Managing Director, Research & Innovation Anticipated completion date: June 30, 2024

Audit Finding Reference: 2023 - 001 Planned Corrective Action: At this time, all files selected for the audit have corresponding records successfully submitted to the Department of Housing and Urban Development through the PIH Information Center ("PIC") submission portal. BRHP will continue weekly PIC submissions and clearing of fatal errors. The late PIC submissions identified were a result of late 50058 approvals which resulted in late PIC submission. The 50058's were uploaded to PIC within 5 days of the approval. BRHP monitors 50058's related to moves in a weekly leasing report. In addition, BRHP meets biweekly to discuss the report. BRHP will monitor the weekly leasing report to review the lease effective dates to HAP executed dates to ensure the actions are approved timely. Name of Contact Person: FaShaunDa Walton, Housing Mobility Director Anticipated completion date: June 30, 2024

Coronavirus State and Local Fiscal Recovery Funds – 21.027 Recommendation: We recommend the Organization adopt a written procurement policy to be used when selecting vendors. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Willis Dady’s Executive Director and Facilities Director will develop a written procurement process for approval from the agency Finance Committee and Board of Directors. Name(s) of the contact person(s) responsible for corrective action: Alicia Faust, Executive Director Planned completion date for corrective action plan: 6/3/2024 If there are questions regarding this plan, please call Alicia Faust, Executive Director at 319-362-7555. Willis Dady Emergency Shelter, Inc. respectfully submits the following summary schedule of prior audit findings for the year ended December 31, 2023. Audit period: January 1, 2023 – December 31, 2023 The findings from the prior audit’s schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the prior year.

United Way of the Greater Lehigh Valley experienced two major events that coincided. First, a forced system change due to the discontinuation of a shared CRM. This caused delayed engagement between the prior CRM, new CRM, and financial software. Second, unprecedented staff turnover (more than 90%) due to retiring leadership. These two issues drove items noted here by auditors. All staff positions have been filled and fortified, all systems have been adjusted, standards have been updated, and processes have been further documented. An example includes proper financial closing processes by the 10th business day, which will provide sufficient time for financial analysis to identify and address concerns to executive and management teams.

Recommendation: We recommend that the City adhere to the Compliance and Reporting Guidance for the SLFRF program and establish internal controls to ensure the City submits required reports when they are due. Views of Responsible Officials: The City has changed the process to submit their Quarterly reports. Reports are reviewed by the Grants Administration Department and Finance Department before they are submitted. Reports have been submitted to the U.S Treasury on a timely basis. Proposed Completion Date: Fiscal Year 2023-2024 Contact Person: Ascencion Alonzo, Director of Finance, City of Edinburg 169

2023‐002. Preparation of Consolidated Financial Statements and Related Footnotes Recommendation: This control deficiency is not unusual in a small company. However, it is the responsibility of management and the board of directors to decide whether to accept the degree of risk associated with this condition based on the cost of correction and other considerations. Management’s Response and Actions Planned: The Company’s management is aware of this significant deficiency. Management reviews and approves the draft annual audited financial statements and distributes them to the users. For entities of this size, it generally is not practical to obtain the internal expertise needed to handle all aspects of the external financial reporting. Management recognizes this and feels it is effectively handling its reporting responsibilities with the procedures described above.

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party: Name: Rodney Potter Position: Assistant Executive Director Telephone Number: (816) 364-3827 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities – Section 811 Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comments on Finding The Maples Housing Corporation agrees with the auditors’ finding and recommendation. Corrective Action(s) We will adopt a policy to ensure tenants requesting maintenance of property via work orders is being maintained properly and efficiently in the work order system and we will review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. Anticipated Completion Date July 31, 2024

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Finding 2023-002 Responsible Party: Name: Rodney Potter Position: Assistant Executive Director Telephone Number: (816) 364-3827 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities – Section 811 Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statements and Federal Awards Auditee’s Comments on Finding The Maples Housing Corporation agrees with the auditors’ finding and recommendation. Corrective Action(s) We will ensure a current and approved HUD Form 9839-B is on file. The form was submitted to HUD for approval on March 22, 2023 and approval not received to-date. Anticipated Completion Date July 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023.

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party: Name: Rodney Potter Position: Assistant Executive Director Telephone Number: (816) 364-3827 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities – Section 811 Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comments on Finding The Maples Housing Corporation agrees with the auditors’ finding and recommendation. Corrective Action(s) We will adopt a policy to ensure tenants requesting maintenance of property via work orders is being maintained properly and efficiently in the work order system and we will review the accuracy / completeness of the documentation being processed in the work order system on a quarterly basis. Anticipated Completion Date July 31, 2024

Finding Summary: The Commission does not have a review process in place to ensure that a person other than the person who prepares the reports for submission review the reports for accuracy for the monthly VMS submission and yearly unaudited REAC submission. Responsible Individuals: Brett Bill, Executive Director Corrective Action Plan: Based on continued turnover in the accounting and finance departments, the review process was not able to be put into action. We have developed the process to ensure a review will occur prior to reports being submitted to HUD on a monthly or annual basis. Anticipated Completion Date: 6/1/2024

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 Special Education Cluster Special Education Grants to States and Special Education Preschool Grants Federal Assistance Listing Numbers, 84.027 and 84.173. COVID-19 Education Stabilization COVID-19 Education Stabilization Federal Assistance Listing Numbers, 84.425, 84.425C, 84.425D, 84.425U, and 84.425W Twenty-First Century Community Learning Centers Twenty-First Century Community Learning Centers Federal Assistance Listing Numbers, 84.287 and 84.287C 2023-001: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: 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. Condition: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management also has not adopted and implemented standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Questioned Costs: None reported. Context: Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. The City did not have an adequate system of internal controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Lack of documented policies, procedures and guidelines in place to ensure compliance with time and effort reporting requirements. Repeat Finding: This matter was reported as a finding for the Title I major program and special education cluster grants in the previous year as finding 2022-001. Recommendation: Management should establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management should also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training should be provided to ensure that the program managers fully understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures will indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and will indicate due dates for when this information must be provided to the school business office. Management will also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training will be provided to ensure that the program managers fully understand the time and effort reporting requirements. Management intends to implement these procedures in fiscal 2024. If the Oversight Agency has questions regarding this plan, please call Michael Pfifferling, Assistant Superintendent of Finance and Operations at 978-374-3400. Sincerely yours, Michael Pfifferling Assistant Superintendent of Finance and Operations City of Haverhill

Recommendation We recommend that the District follow the guidance in NM PED’s PSAB Supplement 13, Purchasing. Management Response Corrective Action: We will work with the District staff to plan and obtain purchase orders before receiving items and/or placing orders. Due Date of Completion: June 30, 2024 Responsible Party(ies): Business Manager

Finding 2023-003: 2023-003 - Significant Deficiency in Internal Control over Compliance and Noncompliance – Allowable Costs/Cost Principles Contact: Michael Bailey, Chief Financial Officer Corrective Action Plan: The Accounting department at Alaska Behavioral Health has stabilized staffing in accounting personnel, including the replacement of the Chief Financial Officer. Prior to submission of financial reports, the CFO will review and verify that personnel related expenditures are supported by payroll allocation records, and other direct expenditures have adequate documentation associated with the allowable expenditure. Proposed Completion Date: 06/30/2024

NCC conducted staff training to reinforce requirements for the return of funds within 240 days for all federal award checks returned uncashed. Effective November 2023, we implemented an automated process to assist with identifying federal funds that need to be returned.

The HEERF reports are being updated, approved and uploaded to our website.

The attendance process has been moved to the Registrar’s Office and registration status codes for unofficial withdrawals have been created in order for the system to find those students when submitting monthly enrollment reporting to clearinghouse, which is then sent to NSLDS.

Christopher M. Sandini, Sr. Director of Finance / Comptroller Phone: (508) 553-4864 E-mail: csandini@franklinma.gov Thursday, April 11, 2024 RE: 2023-001 Improvement Time and Effort Documentation Planned Corrective Action Plan For each employee being charged to a Federal Grant, time and effort documentation for that employee will be maintained that shows their name, school, position, percentage (FTE) charged to the grant, the grant name, the school year and the grant period. It will be signed by both the employee and their supervisor. Anticipated Completion Date: 4/11/24 Sincerely, Christopher M. Sandini, Sr. Director of Finance / Comptroller