Corrective Action Plans

Finding 2022-001 - Lack of Segregation of Duties The District understands that this is a significant deficiency but feels it is not cost-effective at this time to hire additional employees to properly segregate duties. We feel that the oversight performed by the Superintendent and Board of Education over the financial statement activity and reports of the District is adequate to help mitigate the lack of segregation of duties. We believe it would be inefficient and cost prohibitive to hire the additional employees needed to properly segregate duties so at this time we do no plan on making any changes. However, we will continue to monitor this situation and periodically determine if it is cost-effective for us to properly segregate duties.

Finding 2022-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve funds. Responsible Individuals: Amy Kreidt, CEO/Administrator and Brenda Thronburg, Accountant Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the Organization's reserve fund is completed with formal documentation noting the review. Anticipated Completion Date: 3/31/2023

Finding 2022-002 Responsible Party Name: Ju Chinnery Position: Property Accountant Telephone Number: (816)246-9220 PALESTINE GARDENS, INC. 2627 EAST 33RD STREET KANSAS CITY, MO 64128 48 Federal Agency Department of Housing and Urban Development Federal Program Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Sec 207/223(F)) Compliance Requirements N ? Special Tests and Provisions Finding Type Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will deposit the shortfall of $912 into the reserve for replacement account. Anticipated Completion Date June 30, 2023

Finding 2022-003 Responsible Party Name: Ju Chinnery Position: Property Accountant Telephone Number: (816) 246-9220 Federal Agency Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements N ? Special Tests and Provisions Finding Type Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will follow our procedure to ensure tenants requesting maintenance of property via work orders are completed in a timely manner and required documentation is retained in our records. Anticipated Completion Date May 4, 2023

Finding 2022-002 Responsible Party Name: Ju Chinnery Position: Property Accountant Telephone Number: (816) 246-9220 Federal Agency Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements N ? Special Tests and Provisions Finding Type Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will compare the security deposit liability to the security deposit asset each month as part of our monthly closing process. Anticipated Completion Date June 30, 2023

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2022 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, 2022. Finding 2022-001 Responsible Party Name: Ju Chinnery Position: Property Accountant Telephone Number: (816)246-9220 Federal Agency Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements N ? Special Tests and Provisions Finding Type Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action As of the date of the audit report, we have deposited the shortfall of $14,056 into the reserve for replacement account. Anticipated Completion Date May 4, 2023

Significant Deficiency ? Annual Financial Reporting Under Generally Accepted Accounting Principles (GAAP) Fiscal Year: 2022 District?s Response: We concur. Views of Responsible Officials and Corrective Action: The District has made a cost/benefit decision to have the audit firm prepare drafts of its annual financial statements in accordance with GAAP and to prepare the Schedule of Federal Expenditures of Awards. The District will continue to review the draft of the annual financial statements and the Schedule of Federal Expenditures of Awards and raise questions and/or concerns before the statements are released. Name of Responsible Person: Jenifer Frank, Business Manager Projected Implementation Date: Estimated, June 2023

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

Finding 2022-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance ? N. Special Tests and Provisions - Recording of Declarations of Trust/Declaration of Restrictive Covenants Against Public Housing Property Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: A current Declaration of Trust ("DOT"), in a form acceptable to HUD, must be recorded against all public housing property owned by PHAs (or private entities for public housing developed under 24 CFR Part 905, Subpart F) that has been acquired, developed, maintained, or assisted with funds from the US Housing Act of 1937. A DOT is a legal instrument that grants HUD an interest in public housing property. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were properties that the Authority owns and insures that did not have DOTs on file during the time of audit. Context: The Authority owns six (6) public housing properties. During the audit, it was noted that two (2) out of six (6) public housing properties did not have DOTs on file. Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to the recording of DOTs against public housing property. The Authority has not properly filed DOTs in compliance with program requirements. Effect: The Public and Indian Housing Program is in non-compliance with the special tests and provisions type of compliance related to the recording of DOTs against public housing property. 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 DOTs are recorded. Allison Landrum, Chief Executive Officer, is responsible for implementing this corrective action by September 30, 2023.

Finding 2022-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Programs Federal Catalog Numbers: 14.871 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 489 units with failed inspections. Of a sample size of twenty-five (25) failed inspections, three (3) failed inspections did not pass reinspection within 30 days. HAP was not abated nor was the tenant evicted. Our sample size is statistically valid. 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 Section 8 Housing Choice Vouchers Program is 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. The affected files relate to the software conversion from HAB to Yardi. BHA has completed the software conversion, and this should not be an issue going forward. Allison Landrum, Chief Executive Officer, is responsible for implementing this corrective action by September 30, 2023.

Finding 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency 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 1,805 units. Of a sample size of thirty-one (31) tenant files, the following was noted: ? Annual inspection report was missing in 1 file ? HUD 50058 Form was missing in 1 file ? Verification of income and assets was missing in 1 file. Our sample size is statistically valid. Cause: There is a significant deficiency 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 Section 8 Housing Choice Vouchers Program is in 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. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward. Allison Landrum, Chief Executive Officer, is responsible for implementing this corrective action by September 30, 2023.

2022 003 Special Tests and Provisions Compliance (Significant Deficiency) Federal program information Funding Agency U.S. Department of Interior Title Indian School Equalization Program Federal Assistance Listing Number 15.042 Questioned Costs None Condition: During our testwork over special tests and provisions, we noted 3 instances where the employee's background and character investigation were not completed before these employees started working, 2 instances where we did not see the certification of investigation and adjudication. Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individual meet standards of character, no less stringent than those prescribed under Subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63), as the Indian tribe or tribal organization establishes. Cause: The School policies were not followed or were not in place. Effect: The School is not in compliance with the special tests and provision compliance requirement. Auditor's Recommendation: We recommend that the School ensure that employees follow the policies and procedures that are in place along with the compliance requirements for the Indian School Equalization Program and ensure that the compliance requirement is being followed. Management Response: ? The HR department is currently following a Personnel Checklist for Background Checks revised in SY 22-23. The checklist is to ensure new hires who are on boarding complete the required background checks and other required personnel documents. The board approved the date, verification of completing and I-9 form and additional notes. ? Provide training for administrators and supervisors on the proper hiring and on boarding process following the SASI Personnel Policies & Procedures. Estimated Completion Date: We will work with the auditors and complete by next audit next year. Responsible Party: SASI Administration Team

The Organization plans to reorganize job duties and increase staff in the finance department to assist in the preparation of quarterly fiscal and programmatic reports to file on a timely basis. This was a result of staff turnover which created delays in filing complete and accurate reports.

Finding 2022-002 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster FAL #: 84.063, 84.007, 84.268, 84.033 Finding Summary: 34 CFR Section 668.22 states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date. During our testing of compliance with Return of Title IV Funds (R2T4), there was 1 instance out of 38 where the District calculated the incorrect amount to be returned to the Department of Education (ED). Responsible Individuals: Heidi Balster, Director of Student Financial Aid Corrective Action Plan: During each payment period of an award year, the Financial Aid Office will review 20% of all R2T4 calculations (unduplicated) to ensure accuracy of the calculation and students? earned aid. The Financial Aid Office will use the random (RAND) formula in Excel to randomly select the R2T4 student population for testing. Within one week after all midterm grades are posted for the payment period, the Financial Aid Office will randomly select 10% of R2T4 calculations processed and review each calculation to ensure the correct period of enrollment was used in the calculation. After the end of each payment period, within a week after all unofficial withdrawals are processed, the Financial Aid Office will randomly select an additional 10% of R2T4 calculations (unduplicated) and review each calculation to ensure the correct period of enrollment was used in the calculation. If it is determined that a student?s R2T4 calculation is incorrect, the Financial Aid Office will complete the following steps prior to processing a corrected R2T4 calculation: 1. Obtain screenshots of incorrect R2T4 calculation and print copies into the Perceptive Content imaging system 2. Purge the incorrect R2T4 calculation and leave comments in student?s record for reason of purged calculation 3. Update all Title IV aid awards back to original amounts disbursed prior to R2T4 calculation 4. Run the Colleague?s Batch FA Transmittal Register (FATR) process and review aid adjustments 5. Notify the Business Office to have them run the Batch FA Transmittal Update (FATP) process 6. Once FATP is processed, re-run R2T4 calculation with the corrected enrollment Anticipated Completion Date: January 2023

Management's Response: Hopeworks will implement a quarterly tracking system to ensure the grants achieve the 25% matching requirement. On a quarterly basis the Jessica Delgado the Quality and Compliance Officer will send the Finance Department a listing of applicable expenses incurred to date. The Finance Department will review these costs to the Medicaid billings to ensure the 25% match is being met. In the event of a shortfall Finance will coordinate with Quality and Compliance to adjust spending and/or Medicaid billings to bring the matching contribution into alignment with the grant's requirements.

2022-002 Eligibility Recommendation: The College implement procedures in order to strictly comply with the requirements of 34 CFR 668.173 as it relates to the return of Title IV funds. Corrective Action Taken: The College's Financial Aid Office has implemented new procedures. When final high school transcripts come in during a semester, the Office will add a step to review the actual graduation date to make sure that the College is not paying a student for an ineligible semester. Anticipated Completion Date: Fall semester 2022.

FINDING - MAJOR FEDERAL AWARD PROGRAM UNIT 2022-001 Special Test and Provisions - Return of Title IV Funds Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR 668.32 as it relates to student eligibility. Corrective Action Take: The College has well defined policies and procedures that outline attendance requirements and the process for administratively withdrawing students who have met the criterion for 14 consecutive calendar days of non-attendance. Instructors are required to adhere to the College policies. As referenced in 34 CFR 668.173(c)(2), "The Secretary does not consider an institution to be out of compliance with the reserve standard under 668.173(a)(3) if the institution is cited in any audit or review report because it did not return unearned funds in a timely manner for one or two students, or for less than 5% of the students in the sample referred to in paragraph (c)(1)(i) of this section". This audit indicates that only one student was found outside of the allowable timeframe in the sample. The College understands the necessity to reduce any issues with return of funds and will continue to work with instructors on a regular basis to adhere to the policies and procedures established to stay in compliance with these regulations. Anticipated Completion Date: Fall semester 2022 and ongoing.

Reference Number: 2022-001 Name of Contact Person: Trisha Isom, Housing Manager Corrective Action: The City agrees with the finding and will review and monitor each loan to maintain the most up-to-date information and comply with all requirements of the loan program. Proposed Completion Date: June 30, 2023

2022-002 Student Financial Aid Cluster - CFDA No. 84.268 Recommendation: We recommend the Seminary review its procedures around reporting to COD to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will send multiple Title IV Form notices throughout the academic year. Regular reviews will be conducted regarding enrolled students and completed Title IV forms and outreach will occur for any students receiving financial aid that do not have a completed Title IV Form on file. Any students without a Title IV Form will receive a refund within the 14 day period until the Title IV Form has been secured. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registrar Planned completion date for corrective action plan: June 30, 2023

2022-001 Student Financial Aid Cluster - CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary's last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will implement a review of the listing of all potential unofficial withdrawals to ensure effective dates of withdrawal are determined correctly and will also revisit its policies and procedures around NSLDS reporting to ensure all student enrollment statuses are reported correctly and timely to NSLDS as required. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registrar Planned completion date for corrective action plan: June 30, 2023

Item 2022-005 Condition: During the process of identifying expenses and capital costs that were incurred to prevent, prepare for or respond to the coronavirus pandemic, management included capital items for which there was a lack of supporting documentation. Planned Corrective Action: Management agrees with the noted finding. However, the Hospital had also incurred sufficient unreimbursed expenses that if the noted questioned costs had not been reported, the Hospital would have satisfactorily incurred eligible expenses in excess of the PRF funds received, including interest earned on such funds. Management will continue to refine processes to more diligently review expenses to ensure that expenses are not being utilized for reimbursement from multiple sources. Contact Person: Amanda Davidson, Chief Financial Officer Anticipated Completion Date: Ongoing

Reporting views of responsible officials and planned corrective actions Management put in place an electronic work order system that keeps track of the work orders for the property and has put controls in place to actively monitor the system to ensure appropriate repairs are being completed in a timely manner.

Reporting views of responsible officials and planned corrective actions Management will put in place procedures to ensure verification of tenant assets is done during recertification.

Corrective Action Plan December 20, 2022 Cognizant or Oversight Agency for Audit: Douglas County School District No.77 respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: KDP Certified Public Accountants, LLP 841 O?Hare Parkway, Ste. 200 Medford, OR 97504 Audit period: July 1, 2021 to June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are listed below, including the adopted plan of action and timeframe for each: Federal Award Finding U.S. Department of Education Education Stabilization Fund - Assistance Listing No. 84.425 Significant Deficiency 2022-001 Special Tests and Provisions Statement of Condition: The District was not in compliance with the Uniform Guidance as it was noted that management of the District was not collecting certified payroll reports for construction projects charged to the Education Stabilization Fund. Recommendation: We recommend the District review their internal controls to strengthen the processes and improve procedures. We recommend the District notify all contractors and subcontractors of required submission of certified payroll reports prior to the start of any contracted work spent with federal assistance funds exceeding $2,000. Plan of Action: Douglas County School District No. 77 will upon executing any contracts for construction projects charged to the Education Stabilization Fundwill require submission of certified payroll reports. Each contract will state within the contract that contractor and/or subcontractor will provide these reports with each invoice billing. Date of implementation: Effective immediately, any contracts executed after the date of this letter will include the additional language. If the U.S. Department of Education has any questions regarding this plan, please call Racheal Aiken at 541-440-4796. Sincerely yours, Racheal Aiken Assistant Business Director Douglas ESD

March 2, 2023 Shenandoah Area Agency on Aging respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, Virginia 22801 Audit period: September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT 2022-004: Authorized Signer for Bank Accounts Condition: Four bank confirmations signed by the executive director were sent to financial institutions holding SAAA assets as part of our audit were denied due to being signed by an unauthorized individual. Criteria: As part of management's responsibility to safeguard assets, the authorized signer for bank accounts should be documented. Cause: Management was unaware the listing of authorized check signers had not been updated by the bank as requested. Effect: It is critical for an entity to be able to access its cash deposits held by financial institutions. When a listing of authorized signers is not updated, the entity opens itself to opportunities for loss. Terminated employees may still have access to organizational assets or the organization may be prohibited from accessing their accounts at financial institutions if there is no perceived authority to access the funds. FINDINGS-FINANCIAL STATEMENT AUDIT (Continued) 2022-004: Authorized Signer for Bank Accounts (Continued) Recommendation: Management or governance should determine who has access to bank accounts and ensure only the appropriate parties maintain ongoing access for the safekeeping of the organization's assets. Planned Corrective Action: This finding was caused by the bank not updating its signature cards as requested by the Agency. This finding was immediately corrected once identified by the auditors. 2022-005: Material Audit Adjustments Condition: During the audit, we detected one material misstatement in the trial balance presented to us to begin our audit that was considered a material audit correction. Criteria: Generally accepted auditing standards dictates that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Cause: Financial information was missing or inaccurate. Effect: Assets and liabilities were overstated. Recommendation: We recommend that management implement a process to ensure accuracy of balance sheet and statement of activity accounts. Planned Corrective Action: Management agrees with the finding. During the last quarter of the fiscal year, the finance department experienced a vacancy. As a result, we were short-handed. There was one account that was not reconciled in a timely manner. After the year end, the position has since been filled. All significant balance sheets will be reconciled in a timely manner as in previous years. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-001: Cost Sharing Fees, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition services and Special Programs for the Aging-Title III, Part C2 - Nutrition services, Program income Condition: Individuals receiving Title III-C funded services for home delivered meals were charged cost sharing fees. Criteria: Agencies providing services funded under the Title III-C programs may not charge cost sharing fees for the Title 111-C services under Title III-C per 42 U.S. Code? 3030 c-2(a)(2). Cause: No controls or processes were in place to prevent cost sharing fees being charged to individuals receiving services provided under Title III-C programs. Effect: The cost sharing fees for Title III-C services are not allowed under federal guidelines and therefore these fees are considered a questioned cost. Questioned Cost Amount: $4,400 Perspective Information: Noted two fees were charged for Title 111-C services out of a sample of twenty-five cost sharing fees. Recommendation: Cost sharing fees are not allowed to be charged for Title III-C services provided to individuals. Only voluntary contributions may be made for these services. Management should implement procedures to ensure these fees do not continue to be charged. Planned Corrective Action: Management agrees with the finding. As noted in finding 2022-005, the vacant position, which has now been filled, was responsible for compliance review. Additional procedural reviews and corrected report formatting have been implemented to prohibit cost-sharing fees from being charged to the program. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-002: Unallowable Costs, ALN 93.053 Nutrition Services Incentive Program, Allowable Costs Condition: Administrative expenditures were improperly classified as expenditures funded by the Nutrition Services Incentive Program (NSIP). Criteria: NSIP funds may only be used to purchase domestic foods as outlined under Title 7 U.S. Code of Federal Regulations Part 250.68, Nutrition Services Incentive Program. Grant funding received through NSIP may not be used to pay for administration or other services. Cause: Unallowable costs were improperly classified to the financial records supporting NSIP expenditures and allowable costs were improperly allocated to other projects. Effect: Financial records supporting costs expensed under the NSIP award do not reflect the nature of the expenditures requested for reimbursement. Expenditures were misclassified within the financial records to improper programs and thus are considered a questioned cost. Questioned Cost Amount: $98,327 Perspective Information: Noted in one out of a sample of twenty-five expenditures charged to the Aging Cluster. Two of the items in the sample were expenditures charged to NSIP. We reviewed the list of the remaining expenditures charged to NSIP and confirmed the sample was representative of the entire population. Recommendation: It is critical for the underlying financial records to support an organization's claims for costs reimbursements under federal award programs with adequate documentation. Staff must allocate costs appropriately for allowable costs under each federal program and ensure expenditures charged to the federal programs are for appropriate purposes and are properly classified in the records to avoid noncompliance with federal regulations and program requirements. Planned Corrective Action: Management partially agrees with the finding. We agree that certain amounts were misapplied to the NSIP account. However, the funds did purchase food as required by the grant. We believe this to be a reporting error and not a misuse of grant funds. With the vacant position recently filled, we have added additional review procedures to prevent any reoccurrence of misapplication. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-003: Annual Reporting to VDARS, ALN 93.044 Special Programs for the Aging- Title III, Part B- Grants for Supporting Services and Senior Centers, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition Services, ALN 93.053 Nutrition Services Incentive Program, Reporting Condition: The 13th Aging Monthly Report required by the pass through agency, Virginia Department of Aging and Rehabilitative Services (VDARS) was not submitted timely and contained inaccurate revenue and expenditure data. Criteria: VDARS requires the annual I3th Month Aging Monthly Report to be submitted by November 15t?h The report must contain complete and accurate information as a restating of the monthly reporting for the fiscal year. Cause: The 131 Aging Monthly Report was not reconciled to underlying financial records, resulting in unexplained differences between the report and trial balance provided as part of the audit. Additionally, the report was not submitted by November 15, 2022. Effect: The submission of the 13th AMR was not performed timely and included data that did not agree to underlying financial records. This should have been caught during the course of a review process before submission. Therefore, it is considered a significant deficiency of internal controls over compliance. Recommendation: Ensure reporting is submitted timely by the deadline stated by VDARS. Implement a review process for each monthly submission, including documentation of the review. Reconcile the federal, state and local totals reported in the Aging Monthly Report to the underlying financial records as stated in the financial system to ensure accuracy before submission to VDARS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The AMR report was not filed in a timely manner. As noted in finding 2022-0005, the vacated position during the last quarter of the year was responsible for submittals. We note that the report has since been filed. With the position being filled, we believe the 13th AMR will be filed in a timely and accurate manner as in previous years. If the Federal Audit Clearinghouse has questions regarding this plan, please call Cindy Donaldson, Director of Finance at 540-635-7141. Sincerely yours,