Corrective Action Plans

Establishment of a Formal Procurement Policy – My Project USA recognizes the absence of a Federal Procurement Policy within our organization. To address this gap, Zerqa Abid will be tasked with the development of a comprehensive procurement policy. This policy will be subsequently presented to the board of directors for their approval, with the aim of finalizing and implementing it by December 2023.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction Cluster Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 6722086; 2022 Compliance Requirement Affected: Special Provisions Award Period: Year Ended December 31, 2022 Recommendation: We recommend procedures and controls be implemented to ensure authorization to proceed is obtained prior to project costs being incurred for any Federal Highway Administration project. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement procedures with proper internal controls to ensure all authorizations are obtained on highway projects. Name of the contact person responsible for corrective action: Ashley Kurtz, Auditor/Treasurer Planned completion date for corrective action plan: December 31, 2023

We are working in implementing adequate internal control procedures in order to comply with the submission of all required information for the Single Audit for Fiscal Year 2023.

REFERENCE # 2022-005 PERIOD OF PERFORMANCE – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Questioned Costs: Cannot be determined Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Corrective Action Plan: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

REFERENCE # 2022-003 OTHER - BASIS OF ACCOUNTING – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Basis of Accounting —Uniform Guidance states the basis of accounting used may be a special purpose framework. However, it does state that the determination of when an award is expended must be based on when the activity related to the federal award occurs. Uniform Guidance also states for Grants, cost reimbursement contracts, cooperative agreements, and direct appropriation type of contracts, the federal expenditure or expense should be reported when the transaction occurs. Uniform Guidance further states, the auditee should also be able to reconcile amounts presented in the financial statements to related amounts in the schedule of expenditures of federal awards. Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division report to the pass-through entity on an accrual basis. Division’s schedule of expenditures of federal awards is presented on the accrual basis of accounting. Of the Sixty (60) files selected for testing: • Five (5) prior year expenditures were included in Division’s current year schedule of expenditures of federal awards. Questioned Costs: Cannot be determined Recommendation: We recommend Division report program expenditures in the year expenditures were accrued. Corrective Action Plan: The Division will report program expenditures in the year expenditures were accrued. Step 1 Action Date: Ongoing Final Implementation Date:h 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

2022-008 Credit Cards Recommendation: We recommend that management follow established policies and procedures for submitting credit card receipts and obtaining supervisor's approval prior to credit card expenses being paid. All support and back up should be maintained. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Action taken in response to finding Enlace Chicago has and follows established policies and procedures for submitting credit card receipts and obtaining supervisor's approval prior to credit card expenses being paid. We were not able to find certain cc holder documentation due to misfiling, but no credit card payment is processed without documentation. A process of signing out filed documentation has been created to establish a system of documenting when a filed document needs to be pulled. We will also improve on the consistency of documenting review and approved by process. Name of the contact person responsible for corrective action: Laura Velazques, Director of Budget and Planning and Myriam Quezada, Assistant Controller Planned completion date for corrective action plan: June 30, 2023For questions regarding this plan, please call Marcella Rodriguez, Co-Executive Director, at 708-577-3373.

Significant Deficiency Immigrant and Refugee Housing Assistance Project 2022-007 Reporting Recommendation: We recommend that management follow established policies and procedures for timely preparation of reports under program requirements financial reports. Documented timing of preparation and approval should be maintained and documented. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Enlace Chicago has continued to review and approve reports prior to submission as required by the state agency. As stated in last year’s finding response, the attestation of review and approval is embedded in the report form provided by the grantor. We will continue to put forth best efforts to take a step further and document preparation and review on the report form to satisfy the internal process requirement. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Budget and Planning Planned completion date for corrective action plan: June 30, 2023

Finding No. 2022-001 Significant Deficiency Personnel Responsible For Corrective Action: Mike Higgins, VP of Development; Ben Johnson, SVP of Programs; and Grant Manager, to be hired Anticipated Completion Date: Completed Corrective Action Plan: Of the six reports selected for testing, the specific grant report found to be 7 days after the deadline fell at a time of employee transition – when a prior employee with responsibility for report filing moved on to another role at another company and a newly created Grants Coordinator position was filled to take over responsibility. Given the timing of the on-boarding process and education around EDA processing, the report was submitted 7 days late. It should be noted that all subsequent reports were submitted timely. With the establishment of the dedicated Grants Coordinator position (the timing of which coincided with the timing of the cited report), improved controls came into place – namely: 1) dual supervisory review of reports between the direct supervisor of theGrants Coordinator position and the legacy supervisory role of the Senior Vice President Programs; 2) a clearer timeline of reporting was established with project management systems and document repositories (e.g., Salesforce, Asana, and Box) with additional reminders in place to ensure adequate notice is provided to individuals responsible for providing information; and 3) there is a structured follow-up process, at periodic intervals, for report review to ensure deadlines are met. Additionally, in 2023, BioSTL created another new position to ensure internal programmatic and financial control for grants – initiating the hiring of a new Grants Manager role that has already been posted to our website and recruiting has begun. This role will have more dedicated time and responsibility for internal controls and be responsible for timeliness on all reporting and to monitor against all compliance requirements – above and beyond existing and previous supervisory review from the VP, Development and SVP, Programs.

Allowable costs Emergency Rental Assistance Program - Federal Assistance Listing Number: 21.023 Recommendation: We recommend that the Organization implement the proper policies and procedures to ensure compliance with 2 CFR section 200.303. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding:. JCS will ensure all expenses are properly allocated to the correct funding source. Name of the contact person responsible for corrective action: Nicole Wheeler, Controller Planned completion date for corrective action plan: June 30, 2024

Reporting Emergency Rental Assistance Program - Federal Assistance Listing Number: 21.023 Recommendation: We recommend that the Organization implement the proper policies and procedures to ensure compliance with 2 CFR section 200.303. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: JCS will adopt a two-step process for grant reporting to ensure that deadlines are properly met. Grant reporting process begin will once the month ends and reports will be reviewed two days before the submission is due to ensure all reporting requirements are satisfied. Name of the contact person responsible for corrective action: Nicole Wheeler, Controller Planned completion date for corrective action plan: June 30, 2024

Recommendation: Policies and procedures should be in place to ensure indirect costs are properly calculated and adequately approved/reviewed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review policies and procedures to ensure indirect costs are properly calculated and adequately approved/reviewed. Name of the contact person responsible for corrective action: Paula Land, Executive Director Planned completion date for corrective action plan: On going

Contact person (s) responsible: Jocelyn Swain, Interim Fiscal Director. Corrective action planned: Management will ensure that the Indirect Cost Rate Proposal is submitted annually and on time. Anticipated completion date: June 1, 2023

The Board Chairman concurs with the findings. The School District was dealing with a shortage of auditors in Montana and the audit started late. Documentation issue was due to the key employee turnover prior to August 2022.

Responsible Official’s Response and Corrective Action Plan In 2022, the Federal Award manager at Associated Black Charities departed mid-year, leading to considerable confusion among the existing management. As we transitioned into 2023, the entire management team underwent changes, resulting in the loss of crucial knowledge about the existing filing system from previous years. With the introduction of new leadership, we are now poised to implement fresh policies and procedures to address our succession planning needs. These updated protocols will outline the process for filing essential information and its specific location, ultimately expediting the audit process. Planned Implementation Date of Corrective Action December 2023 Person Responsible for Corrective Action Travis Curtis, Director of Finance

Responsible Official’s Response and Corrective Action Plan In 2022 and into 2023, there was a significant restructuring of our management team, which resulted in challenges when trying to locate files from the prior administration. In response, management is in the process of formulating new policies and procedures (in addition to the Financial Policies and Procedures implemented in May 2023) specifically designed to address succession planning. The objective is to ensure that critical company knowledge is not concentrated in the hands of a single individual but is instead securely stored on a centralized drive. This approach will facilitate a smoother transition when onboarding new management personnel. Planned Implementation Date of Corrective Action December 2023 Person Responsible for Corrective Action

October 30, 2023 The Town of Vinton respectfully submits the following corrective action plan for the year ending June 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2022 The findings from the June 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 2022-001: Audit Adjustments (Material Weakness) Condition: During the audit, we noted that several year-end audit adjustments were required to ensure that the financials were prepared in accordance with accounting principles generally accepted in the United States of America. The adjustments were related to debt, accounts receivable, and capital assets. Criteria: Audit adjustments were required to correct balances in order for the financial statements to be presented in accordance with accounting principles generally accepted in the United States of America. Cause: With regard to governmental activity long-term debt, it appears that the roll forward was not reviewed before year-end entries were made, resulting in additional adjustments to long-term debt balances. With regard to business-type activities' long-term debt, principal payments were recorded as an expense rather than a reduction to long-term debt, resulting in additional adjustments to these accounts. With regard to governmental activities and business-type activities' accrued interest, amortization schedules were not reviewed before entries were made, resulting in additional adjustments to these accounts. With regard to governmental activities and business-type activities capital assets, roll forwards, and depreciation schedules were not reviewed before entries were made, resulting in additional adjustments. With regard to governmental activities receivables and deferred revenue were not correctly captured and recorded at year end. Effect: There is an increased risk of financial statement misstatement. FINDINGS – FINANCIAL STATEMENT AUDIT (CONTINUED) 2022-001: Audit Adjustments (Material Weakness) (Continued) Recommendation: We recommend establishing procedures in which qualified supervisors are reviewing year-end work papers that feed into the final general ledger and focus on the accuracy of year-end balances. Planned Corrective Action: Management has noted the opportunities for improvement in the review process and segregated duties, as it pertains to audit preparation. Completion of working papers will be completed by Financial and Senior Financial Administrators, then reviewed for correctness by the Finance Director and Treasurer. In addition, the team will work to link the documents to reduce the adjustments of the final documents. 2022-002: Segregation of Duties (Material Weakness) Condition: A fundamental concept of internal controls is the separation of duties. No one employee should have access to both physical assets and the related accounting records, or to all phases of a transaction. A proper segregation of duties has not been established in functions related to accounts payable, accounts receivable, cash disbursements, and information technology. Criteria: • Mail should be opened by an employee not responsible for accounting, such as the Town Clerk. Cash receipts could be recorded and the deposit prepared by this person. The cash receipts journal, supplemented by remittance advice, could be forwarded to the accounting staff for postings to the general ledger and detailed customer accounts. • Customer complaints, returned checks, disputed items, and other such matters should be investigated by someone who is independent of preparing daily cash receipts and deposits. • Checks and remittance advice should be placed into envelopes and mailed by someone with no other accounting responsibilities. • Water and sewer billing should be independent of the accounts receivable function. Cause: The size of the Town’s accounting staff prohibits complete adherence to segregation of duties. Effect: Internal controls are designed to safeguard assets and detect losses from employee dishonesty or error. Recommendation: Steps should be taken to eliminate the performance of conflicting duties where possible or to implement effective compensating controls. FINDINGS – FINANCIAL STATEMENT AUDIT (CONTINUED) 2022-002: Segregation of Duties (Material Weakness) (Continued) Planned Corrective Action: Management noted this finding. The Finance Director has segregated duties, to the extent practical, to minimize instances where the same person has complete control of a transaction or conflicting duties. FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-003: Coronavirus State and Local Fiscal Recovery Fund – AL# 21.027, Late Filling of Data Collection Form Condition: The Town did not file the data collection form for the year ended June 30, 2022, timely. Criteria: For June 30, 2022 year-end audits, under the requirements in the Uniform Guidance and the Office of Management and Budget (OMB), all entities are required to submit the annual data collection form with the Federal Audit Clearinghouse the earlier of either 30 days after the issuance of the entity’s annual audit or twelve months after the entity’s fiscal year end (June 30th for the Town of Vinton plus a three-month extension). Cause: Management did not complete and certify their portion of the form before the deadline. Form cannot be completed before audit is issued. Effect: The entity’s form was submitted to the Federal Audit Clearinghouse late, delaying the completion of all annual audit requirements for the Town. Recommendation: Management should take steps to ensure that the form is filed timely Planned Corrective Action: Management takes note of this finding. The Finance Director is working with the department to ensure reports are completed and the audit is completed in a timely manner.   FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT (CONTINUED) 2022-004: Schedule of Expenditures and Federal Awards (Significant Deficiency) Condition: The Schedule of Expenditures and Federal Awards (SEFA) was prepared without supervisor review resulting in several auditor corrections. Criteria: Segregation of duties and review procedures should be applied to federal award workpapers. Cause: Town has not established written internal control policies with regard to federal awards. Effect: Risk that the Town’s information in the SEFA is not accurate, complete, or appropriately presented in accordance with Uniform Guidance. Recommendation: Management should develop and implement written internal control policies. Planned Corrective Action: Management has noted the opportunities for improvement in the review process and segregated duties, as it pertains to audit preparation. Completion of working papers will be completed by Financial and Senior Financial Administrators, then reviewed for correctness by the Finance Director and Treasurer. If the Federal Audit Clearinghouse has questions regarding this plan, please call Andrew Keen, Finance Director (540) 983-0608 ext. 7012. Sincerely yours, Name: Andrew Keen Title: Finance Director

Finding 2022-002 Recommendation: The Organization’s management should ensure all expenses submitted are reimbursable. Corrective Action: The Organization will ensure someone familiar with allowable costs are preparing the payment reimbursement requests. Person Responsible for Corrective Action: President/CEO Anticipated Completion Date for Corrective Action: The corrective action will be immediately implemented in response to the auditor’s recommendation. If there are questions regarding this corrective action plan, please call Scott Johnson, President/CEO, at (404) 210-1776.

2022-001: Audit Report Submission to the Federal Government Corrective Action Plan: The Board has hired a contract accountant to assist the Accounting Manager in the timely financial close to report and audit preparation to ensure timely completion of their financial and compliance audits. Anticipated Completion: December 31, 2023 Responsible Party: Tamie Wick, Accounting Manager. Amy Terrell, Airport Director.

Action taken in response to finding: County department personnel changes have been implemented which address this deficiency. New department personnel have been properly trained by County Auditor staff as well as State grantor personnel to ensure correct grant reporting. Department supervising staff will monitor grant reporting documentation. All manual adjusting entries will be requested through the County Auditor’s office to ensure proper supporting documentation is provided. Name(s) of the contact person(s) responsible for corrective action: Dave MacDonna, Community Resources Director. Eric Black, Chief Deputy Auditor. Planned completion date for corrective action plan: October 2, 2023

Action taken in response to finding: All required reporting of the Coronavirus State & Local Fiscal Recovery Fund will be sent to the County Administrator for review and approval in a timely manner of the reports being submitted to the Federal reviewing agency. Documentation of review and approval will be kept along with other supporting documentation for the program. Name(s) of the contact person(s) responsible for corrective action: Eric Black, Chief Deputy Auditor Planned completion date for corrective action plan: November 1, 2023

Management's Action Plan: Kevin Holland, Vice-President-Stone County and Operations will oversee the supervisory review and approval of timesheets for the next few pay cycles to ensure management is reviewing 100% of the records. He will also work to ensure none of them are being missed through special circumstances as has happended in the past in order to achieve and sustain 100% compliance. Name of Person Responsible for the Plan: Kevin Holland, Vice-President Stone County & Operations. Anticipated Completion Date of the Plan: 3 payroll cycles spanning six weeks. Approximately mid-December 2023 for completion.

Management agrees with the finding and will review the outstanding checks older than three years and take appropriate action, may it be void the old outstanding check, reissue the check or file voluntary correction forms with the State of NJ.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2022-004 Internal Control Over Compliance with Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal program. The District did not have sufficient controls in place within its child nutrition cluster federal program to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Kerstin Quigley, Business Manager. Planned Completion Date – December 31, 2023. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – The District’s Business Manager and the Superintendent will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

The Company agrees that compliance tracking is pertinent. The Company’s previous Controller tracked all compliance requirements with close cooperation between various departments in the organization. The third-party consultants did not continue tracking certain compliance data which led to the finding. The company has modified their process accordingly to ensure tracking of all compliance requirements.

Information on Federal Program(s) - Department of Health and Human Services, Assistance Listing Number 93.498 COVID-19 - Provider Relief Fund and American Rescue Plan Rural Distribution, Schedule of Expenditures of Federal Awards Reporting Periods 2 and 3, Agency Fiscal Year-Ended June 30, 2022. Management’s Corrective Action Plan In response to the deficiency identified, the Agency will modify its existing internal control protocols in the following ways: • Develop emergency internal control protocols to be implemented during emergency situations whereby all items recoded by accounting staff are reviewed and signed off by the Controller or Director of Finance to ensure appropriate treatment. Train all accounting staff on this expectation. • Ensure adherence of record retention policies and procedures which are consistent with regulatory requirements. • Modify its petty cash protocols to include the review and adequate documentation of all receipts to verify allowability prior to reimbursement. Train all petty cash reviewers on this expectation. Individual Responsible for Corrective Action Plan Auston Johnson Controller 215-386-3838 Anticipated Completion Date: October 31, 2023